(b) State the immediate tax implications of the proposed gift of the share portfolio to Avril and identify an

alternative strategy that would achieve Crusoe’s objectives whilst avoiding a possible tax liability in the

future. State any deadline(s) in connection with your proposed strategy. (5 marks)

(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.

(c) On the assumption that the administrators of Noland’s estate will sell quoted shares in order to fund the

inheritance tax due as a result of his death, calculate the value of the quoted shares that will be available to

transfer to Avril. You should include brief notes of your treatment of the house and the shares in Kurb Ltd.

(9 marks)

Note: you should assume that the tax rates and allowances for the tax year 2006/07 apply throughout this

question.

(b) The tax relief available in respect of the anticipated trading losses, together with supporting calculations and

a recommended structure for the business. (16 marks)

(c) Explanatory notes, together with relevant supporting calculations, in connection with the loan. (8 marks)

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

effectiveness with which the information is communicated and the extent to which the schedules are structured in

a logical manner. (3 marks)

Notes: – you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial year

to 31 March 2007 apply throughout the question.

– you should ignore value added tax (VAT).

(ii) The use of the trading loss of Tethys Ltd for the year ending 31 December 2008; (6 marks)

(iii) Advice in connection with the sale of the manufacturing premises by Tethys Ltd; (7 marks)

5 Gagarin wishes to persuade a number of wealthy individuals who are business contacts to invest in his company,

Vostok Ltd. He also requires advice on the recoverability of input tax relating to the purchase of new premises.

The following information has been obtained from a meeting with Gagarin.

Vostok Ltd:

– An unquoted UK resident company.

– Gagarin owns 100% of the company’s ordinary share capital.

– Has 18 employees.

– Provides computer based services to commercial companies.

– Requires additional funds to finance its expansion.

Funds required by Vostok Ltd:

– Vostok Ltd needs to raise ￡420,000.

– Vostok Ltd will issue 20,000 shares at ￡21 per share on 31 August 2008.

– The new shareholder(s) will own 40% of the company.

– Part of the money raised will contribute towards the purchase of new premises for use by Vostok Ltd.

Gagarin’s initial thoughts:

– The minimum investment will be 5,000 shares and payment will be made in full on subscription.

– Gagarin has a number of wealthy business contacts who may be interested in investing.

– Gagarin has heard that it may be possible to obtain tax relief for up to 60% of the investment via the enterprise

investment scheme.

Wealthy business contacts:

– Are all UK resident higher rate taxpayers.

– May wish to borrow the funds to invest in Vostok Ltd if there is a tax incentive to do so.

New premises:

– Will cost ￡446,500 including value added tax (VAT).

– Will be used in connection with all aspects of Vostok Ltd’s business.

– Will be sold for ￡600,000 plus VAT in six years time.

– Vostok Ltd will waive the VAT exemption on the sale of the building.

The VAT position of Vostok Ltd:

– In the year ending 31 March 2009, 28% of Vostok Ltd’s supplies will be exempt for the purposes of VAT.

– This percentage is expected to reduce over the next few years.

– Irrecoverable input tax due to the company’s partially exempt status exceeds the de minimis limits.

Required:

(a) Prepare notes for Gagarin to use when speaking to potential investors. The notes should include:

(i) The tax incentives immediately available in respect of the amount invested in shares issued in

accordance with the enterprise investment scheme; (5 marks)

4 (a) Explain the auditor’s responsibilities in respect of subsequent events. (5 marks)

Required:

Identify and comment on the implications of the above matters for the auditor’s report on the financial

statements of Jinack Co for the year ended 30 September 2005 and, where appropriate, the year ending

30 September 2006.

NOTE: The mark allocation is shown against each of the matters.

(iv) The stamp duty and/or stamp duty land tax payable by the Saturn Ltd group; (2 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)