通常施工单位都具有实施项目管理的水平和能力，当遇到（）问题时，可能委托专业化建设项目管理公司为其提供相应的服务。

(ii) Explain, with reasons, the relief available in respect of the fall in value of the shares in All Over plc,

identify the years in which it can be claimed and state the time limit for submitting the claim.

(3 marks)

(ii) Assuming the relief in (i) is available, advise Sharon on the maximum amount of cash she could receive

on incorporation, without triggering a capital gains tax (CGT) liability. (3 marks)

(c) Calculate and explain the amount of income tax relief that Gerard will obtain in respect of the pension

contributions he proposes to make in the tax year 2007/08 and contrast this with how his position could be

improved by delaying some of the contributions that he could have made in 2007/08 until 2008/09. You

should include relevant supporting calculations and quantify the additional tax savings arising as a result of

your advice.

You should ignore the proposed changes to the bonus scheme for this part of this question and assume that

Gerard’s income will not change in 2008/09. (12 marks)

(b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of the new premises in the

year ending 31 March 2009 and explain, using illustrative calculations, how any additional recoverable input

tax will be calculated in future years. (5 marks)

According to the text, tax relief schemes were intended to ______.

A．attract more investment into the film industry

B．ensure the interests of investors against losses

C．check the rise of film production expenditures

D．prevent the invasion of overseas film makers

(c) The inheritance tax payable by Adam in respect of the gift from his aunt. (4 marks)

Additional marks will be awarded for the appropriateness of the format and presentation of the memorandum and

the effectiveness with which the information is communicated. (2 marks)

Note: you should assume that the tax rates and allowances for the tax year 2006/07 will continue to apply for the

foreseeable future.

According to the text, tax relief schemes were intended to______.

A．attract more investment into the film industry

B．ensure the interests of investors against losses

C．check the rise of film production expenditures

D．prevent the invasion of overseas film-makers

Section B – TWO questions ONLY to be attempted

Your client, Eric, requires advice on the capital gains tax implications arising from the receipt of insurance proceeds and the disposal of some shares, and the inheritance tax reliefs available in respect of assets in his estate at death. His son Zak requires advice regarding the application of the personal service company (IR35) legislation.

Eric:

– Is UK resident and domiciled.

– Is a higher rate taxpayer.

– Is in ill health and is expected to die within the next few months.

Capital transactions in the tax year 2014/15:

– Eric made no disposals for capital gains tax purposes in the tax year 2014/15 other than those detailed below.

– Eric received insurance proceeds of ￡10,000 following damage to a valuable painting.

– Eric sold half of his shareholding in Malaga plc for ￡11·50 per share.

Damaged painting:

– Eric purchased the painting for ￡46,000 in July 2012.

– The painting was damaged in October 2014 such that immediately afterwards its value fell to ￡38,000.

– The insurance proceeds of ￡10,000 were received by Eric on 1 December 2014.

– Eric has not had the painting repaired.

Malaga plc shares:

– Malaga plc is a quoted trading company with 200,000 issued shares.

– 80% of Malaga plc’s chargeable assets have always been chargeable business assets.

– Eric was given 12,000 shares in Malaga plc by his sister on 1 April 2010, when they were valued at ￡126,000.

– Eric’s sister had purchased the shares for ￡96,000 on 1 March 2009.

– Gift relief was claimed in respect of the gift of the shares to Eric on 1 April 2010.

– Eric paid the inheritance tax arising in respect of this gift following his sister’s death on 1 September 2011.

– Eric has never worked for Malaga plc.

– Eric sold 6,000 shares in Malaga plc on 1 March 2015.

Assets owned by Eric and a previous lifetime gift:

– Eric owns farmland in the UK, which has been leased to a tenant farmer for the last ten years.

– The farmland has a market value of ￡420,000 and an agricultural value of ￡340,000.

– Eric’s other assets, excluding the remaining Malaga plc shares, are valued at ￡408,000.

– Eric has made only one previous lifetime gift, of ￡60,000 cash to his son Zak on 1 July 2009.

Zak:

– Is the sole shareholder, director and employee of Yoyo Ltd, a company which provides consultancy services.

– In the year ended 31 March 2016, Yoyo Ltd’s gross fee income from relevant engagements performed by Zak will be ￡110,000.

– In the tax year 2015/16, Zak will draw a salary of ￡24,000 and dividends of ￡50,000 from Yoyo Ltd.

– Neither Yoyo Ltd nor Zak has any other source of income.

Required:

(a) Calculate Eric’s total after-tax proceeds in respect of the two capital gains tax disposals in the tax year 2014/15. (6 marks)

(b) (i) On the assumption that Eric dies on 31 March 2016, advise on the availability and effect (if any), of agricultural property relief, business property relief and quick succession relief in respect of the farmland and the retained shares in Malaga plc.

Note: You are not required to prepare calculations for this part of the question. (6 marks)

(ii) Explain, with the aid of calculations, the impact on the inheritance tax liability arising on Eric’s death if Eric does not die until 1 August 2016. (3 marks)

(c) Calculate Zak’s taxable income for the tax year 2015/16 if the personal service company (IR35) legislation were to apply to the fee income received by Yoyo Ltd. (5 marks)

(b) (i) Advise Andrew of the income tax (IT) and capital gains tax (CGT) reliefs available on his investment in

the ordinary share capital of Scalar Limited, together with any conditions which need to be satisfied.

Your answer should clearly identify any steps that should be taken by Andrew and the other investors

to obtain the maximum relief. (13 marks)

The following information is available about a company:

The company’s 2012 income tax expense (in thousands) is closest to:

A. $1,000.

B. $1,050.

C. $1,250.