项目总承包模式具有的缺点包括（）

(c) Assuming that she will survive until July 2009, advise on the lifetime inheritance tax (IHT) planning

measures that could be undertaken by Debbie, quantifying the savings that can be made. (7 marks)

For this question you should assume that the rates and allowances for 2004/05 apply throughout.

(ii) State when the inheritance tax (IHT) calculated in (i) would be payable and by whom. (2 marks)

(b) (i) Calculate the inheritance tax (IHT) that will be payable if Debbie were to die today (8 June 2005).

Assume that no tax planning measures are taken and that there has been no change in the value of any

of the assets since David’s death. (4 marks)

(b) Explain the capital gains tax (CGT) and inheritance tax (IHT) implications of Graeme gifting his remaining ‘T’

ordinary shares at their current value either:

(i) to his wife, Catherine; or

(ii) to his son, Barry.

Your answer should be supported by relevant calculations and clearly identify the availability and effect of

any reliefs (other than the CGT annual exemption) that might be used to reduce or defer any tax liabilities

arising. (9 marks)

(ii) State, giving reasons, the tax reliefs in relation to inheritance tax (IHT) and capital gains tax (CGT) which

would be available to Alasdair if he acquires the warehouse and leases it to Gallus & Co, rather than to

an unconnected tenant. (4 marks)

(b) Calculate the inheritance tax (IHT) liability arising as a result of Christopher’s death. (11 marks)

(b) Mabel has two objectives when making the gifts to Bruce and Padma:

(1) To pay no tax on any gift in her lifetime; and

(2) To reduce the eventual liability to inheritance tax on her death.

Advise Mabel which item to gift to Bruce and to Padma in order to satisfy her objectives. Give reasons for

your advice.

Your advice should include a computation of the inheritance tax saved as a result of the two gifts, on the

assumption that Mabel dies on 30 June 2011. (10 marks)

(c) (i) Explain the inheritance tax (IHT) implications and benefits of Alvaro Pelorus varying the terms of his

father’s will such that part of Ray Pelorus’s estate is left to Vito and Sophie. State the date by which a

deed of variation would need to be made in order for it to be valid; (3 marks)

James died on 22 January 2015. He had made the following gifts during his lifetime:

(1) On 9 October 2007, a cash gift of ￡35,000 to a trust. No lifetime inheritance tax was payable in respect of this gift.

(2) On 14 May 2013, a cash gift of ￡420,000 to his daughter.

(3) On 2 August 2013, a gift of a property valued at ￡260,000 to a trust. No lifetime inheritance tax was payable in respect of this gift because it was covered by the nil rate band. By the time of James’ death on 22 January 2015, the property had increased in value to ￡310,000.

On 22 January 2015, James’ estate was valued at ￡870,000. Under the terms of his will, James left his entire estate to his children.

The nil rate band of James’ wife was fully utilised when she died ten years ago.

The nil rate band for the tax year 2007–08 is ￡300,000, and for the tax year 2013–14 it is ￡325,000.

Required:

(a) Calculate the inheritance tax which will be payable as a result of James’ death, and state who will be responsible for paying the tax. (6 marks)

(b) Explain why it might have been beneficial for inheritance tax purposes if James had left a portion of his estate to his grandchildren rather than to his children. (2 marks)

(c) Explain why it might be advantageous for inheritance tax purposes for a person to make lifetime gifts even when such gifts are made within seven years of death.

Notes:

1. Your answer should include a calculation of James’ inheritance tax saving from making the gift of property to the trust on 2 August 2013 rather than retaining the property until his death.

2. You are not expected to consider lifetime exemptions in this part of the question. (2 marks)

(c) Explain the capital gains tax (CGT) and income tax (IT) issues Paul and Sharon should consider in deciding

which form. of trust to set up for Gisella and Gavin. You are not required to consider inheritance tax (IHT) or

stamp duty land tax (SDLT) issues. (10 marks)

You should assume that the tax rates and allowances for the tax year 2005/06 apply throughout this question.