(b) Given his recent diagnosis, advise S - 试题及答案

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(b) Given his recent diagnosis, advise S

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[试题](b) Given his recent diagnosis, advise Stuart as to which of the two proposed investments (Omikron plc/Omega
plc) would be the more tax efficient alternative. Give reasons for your choice. (3 marks)

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解析：(b) Both companies are listed. The only difference will be in the availability of inheritance tax relief – specifically business propertyrelief (BPR). If Stuart and Rebecca jointly hold in excess of 50% of the share capital of a listed company, BPR will apply atthe rate of 50%. Otherwise, no BPR is available.Stuart can only buy 1,005,000 (￡422,100/￡0·42) shares in Omikron plc. This represents a shareholding of 2·00%(1,005,000/50,250,000). As the shares in Omikron plc are listed, a 2% holding will not qualify for BPR.At the moment, both Stuart and Rebecca own 2,400,000 shares in Omega plc. Their shareholdings are amalgamated forIHT purposes under the related property rules. With a joint holding of 48%, BPR is not available. A further 200,001 shareswill be required to attain a 50% holding. Assuming Stuart and Rebecca can buy these shares, they must then hold their 50%interest in the company for the period of at least two years in order to ensure that BPR applies.On the basis that Stuart is expected to survive for two to three years, he should therefore buy further shares in Omega plc inorder to take advantage of the BPR available.
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