Registered AITI Tax Qualification Info and Questions

smpc · 09-06-2011 08:16PM

K Settes wrote: »

I could have sworn I saw somewhere on the website - the font, size and line spacing they wanted for the assignment. I can't seem to find it now. Did I imagine it? Or is there a specific way they want it presented?

i think mine will be in or around 10,000 words when i am finished.

yeah i rememeber this too! but have not seen it and i have been searching but i do remember reading it.

did everyone get the email today re home assignment. they meantioned forums on it and that if you sourced info from a forum that it should be referenced.

K Settes · 09-06-2011 10:12PM

I saw that in the e-mail alright - I presume that means they are watching us so!

(Big wave to the ITI!)

The interest payments - I'm only thinking out loud here - so would love some feedback on it....

The loan is obviously long term in nature and not short interest and so is a yearly interest payment.

The choices with the interest payments are that they will be made to either an EU country or a non EU country

s246 - means WT has to be decuted on the interest payment to the non resident.

But as Lux is EU, the destination country is EU member and so exemption applies to WT.

I think s835 applies in terms arms length transaction for interest payments

Am I on the right track?

smpc · 09-06-2011 10:35PM

K Settes wrote: »

I saw that in the e-mail alright - I presume that means they are watching us so! (Big wave to the ITI!)

The interest payments - I'm only thinking out loud here - so would love some feedback on it....

The loan is obviously long term in nature and not short interest and so is a yearly interest payment.

The choices with the interest payments are that they will be made to either an EU country or a non EU country

s246 - means WT has to be decuted on the interest payment to the non resident.

But as Lux is EU, the destination country is EU member and so exemption applies to WT.

I think s835 applies in terms arms length transaction for interest payments

Am I on the right track?

I would agree and I am recommending that we use lux company to avoid W/T and charge MV as lux tax rate is lower than irish rate.

ofjames · 09-06-2011 10:58PM

deco2011 wrote: »

What are people's thoughts on the interest payments?

I simply said that the interest on the loan would be a trading deduction in line with the Sean MacAonghasa Case. Is this the wrong approach?

What date are you proposing these transactions take place? Are we to assume everything happens in 2010?

I also went with S246 and Luxembourg with no WT re the interest.

smpc · 09-06-2011 11:59PM

ofjames wrote: »

I simply said that the interest on the loan would be a trading deduction in line with the Sean MacAonghasa Case. Is this the wrong approach?

What date are you proposing these transactions take place? Are we to assume everything happens in 2010?

I also went with S246 and Luxembourg with no WT re the interest.

i agree re sean macaonghasa case.

had not thought about dates - had gone with 2011 dates (time of writing) but you are right it should be 2010 (as we are working with 2010 leg). gonna adjust them 2moro..

smpc · 10-06-2011 12:02AM

Also I would advise everyone to log into turnitin and set up profile well b4 submission as it took me a few trys to get it figured out -with passwords and all and I would not want to be doing it in a panic in the last hour. only takes 10mins but one less thing to confuse me when submitting.

ascuteasabutton · 10-06-2011 08:12AM

Finally finished Part 2 last night/this morning about 2am...finished with about 10,000 words,happy enough with what I have done but found it tough enough with the R OR Dom status got very confusing in parts as his status was changing over the 3 years!

Have been trying for the last 15 mins to upload the assignment and keep getting an error report...anybody else having problems?

Nicky7520 · 10-06-2011 03:46PM

Guys - Bermuda is better as no tax there and you can apply to avoid WT under Revenue Statement of Practice SP CT 01/10...I think!

Nicky7520 · 10-06-2011 03:48PM

where do i find the CT calendar? I dont have the CT text book...

Nicky7520 · 10-06-2011 04:06PM

Anyone consider the share capitalisation option (I know Rajesh doesnt like it but maybe half a paragraph might get a mark?)

smpc · 10-06-2011 05:57PM

Nicky7520 wrote: »

Anyone consider the share capitalisation option (I know Rajesh doesnt like it but maybe half a paragraph might get a mark?)

i havent looked at this and at this stage dont tink i will be.

smpc · 10-06-2011 05:58PM

Nicky7520 wrote: »

where do i find the CT calendar? I dont have the CT text book...

not sure there is one.

think we just to set out dates that prelim, returns and tax are due. i have assumed a commencement date and prepared a calendar on this basis.

smpc · 10-06-2011 06:01PM

for the compliance calendar i assume that we do not need to look at paye compliance eg p35 due dates etc?

beeftotheheels · 10-06-2011 06:08PM

Nicky7520 wrote: »

Anyone consider the share capitalisation option (I know Rajesh doesnt like it but maybe half a paragraph might get a mark?)

Surely there is a risk you will lose marks if you write irrelevant stuff? If it is relevant by all means write it, if it is not relevant then you could be shooting yourself in the foot by writing it.

Remember, answer the question asked and not the question you wish had been asked.

I have also noted a lot of posts on this thread offering advice to others on technical aspects of the questions. If that advice is incorrect, and shows up in multiple answers, then I would suspect that that could cause you issues too.

Reading this thread the mind boggles...

It is perfectly fine for you to rant on a discussion forum "Grrr the question is so hard, any one else think it is hard?"

It is probably fine to share interesting articles "I thought Article ITR reference here was very helpful"

It is probably fine to have a bit of a discussion around admin e.g. word count and time limits although you really should be checking the Institute guidelines on this.

But it is daft to be asking anonymous users on an anonymous web forum for help with your homework, and it is even more daft to take that advice unless you research it yourself and conclude that you agree with it.

Rant over.

smpc · 10-06-2011 06:27PM

beeftotheheels wrote: »

Surely there is a risk you will lose marks if you write irrelevant stuff? If it is relevant by all means write it, if it is not relevant then you could be shooting yourself in the foot by writing it.

Remember, answer the question asked and not the question you wish had been asked.

I have also noted a lot of posts on this thread offering advice to others on technical aspects of the questions. If that advice is incorrect, and shows up in multiple answers, then I would suspect that that could cause you issues too.

Reading this thread the mind boggles...

It is perfectly fine for you to rant on a discussion forum "Grrr the question is so hard, any one else think it is hard?"

It is probably fine to share interesting articles "I thought Article ITR reference here was very helpful"

It is probably fine to have a bit of a discussion around admin e.g. word count and time limits although you really should be checking the Institute guidelines on this.

But it is daft to be asking anonymous users on an anonymous web forum for help with your homework, and it is even more daft to take that advice unless you research it yourself and conclude that you agree with it.

Rant over.

you will lose marks if something is irrelevant and you will lose marks if something is wrong. you will also lose marks if you miss an important point.

what makes you think that people are not researching points in detail - even if they would not have considered the point had they not seen it on this thread.

If the issue is identified - we can look at it and decide for ourselves if it is relevant, irrelevant, correct or incorrect.

also it does help to talk things through with people who are doing the same research as you.

do you work in tax? in a normal working environment no one gives tax advice in isolation as there can be many angles and it is all too easy to forget one of them.

beeftotheheels · 10-06-2011 06:48PM

smpc wrote: »

do you work in tax? in a normal working environment no one gives tax advice in isolation as there can be many angles and it is all too easy to forget one of them.

I do, and have done for very many years, and have even, in the past, lectured for the Institute.

Often times when dealing with something tricky I would confer with colleagues.

However, if dealing with a tricky company reconstruction I would be unlikely to ask colleagues who specialize in VAT or wealth planning, or employment related tax for their advice. Neither would I ask a trainee for their advice. I would only ask a suitably senior person who I knew had expertise in the area.

I would certainly not post it on a discussion forum where the caliber of replies was at best dubious.

There is also, I might add, a fundamental difference between seeking expert advice when the aim is to provide the best possible advice to your client, from seeking expert advice when doing a paper the aim of which is to test your knowledge. Would getting Judge or Feeney to sit your exam paper on the day not strike you as missing the point?

I managed to get hold of a copy of your question, and some of the posts on this thread are horribly misleading and some are downright wrong.

You are students, I am not, so it would be wrong of me to tell you which posts are wrong or offer any technical answers. However I feel it beholden to me to point out that some of them are wrong.

Hence my post trying to get you all to check that you have not copied someone else's errors before it is too late. I'm only trying to help here.

smpc · 10-06-2011 07:13PM

beeftotheheels wrote: »

I do, and have done for very many years, and have even, in the past, lectured for the Institute.

Often times when dealing with something tricky I would confer with colleagues.

However, if dealing with a tricky company reconstruction I would be unlikely to ask colleagues who specialize in VAT or wealth planning, or employment related tax for their advice. Neither would I ask a trainee for their advice. I would only ask a suitably senior person who I knew had expertise in the area.

I would certainly not post it on a discussion forum where the caliber of replies was at best dubious.

There is also, I might add, a fundamental difference between seeking expert advice when the aim is to provide the best possible advice to your client, from seeking expert advice when doing a paper the aim of which is to test your knowledge. Would getting Judge or Feeney to sit your exam paper on the day not strike you as missing the point?

I managed to get hold of a copy of your question, and some of the posts on this thread are horribly misleading and some are downright wrong.

You are students, I am not, so it would be wrong of me to tell you which posts are wrong or offer any technical answers. However I feel it beholden to me to point out that some of them are wrong.

Hence my post trying to get you all to check that you have not copied someone else's errors before it is too late. I'm only trying to help here.

I think students are using this forumn to discuss issues, I am not putting anything in my paper that I have not researched to the best of my ability.

I understand your concern with regard to the quality of the posts and I appreciate the fact that you are merely trying to help, however, I think students are aware that anything posted on this site cannot be relied on.

This is a home assignment, discussion with colleagues is permitted. Your reference to having Feeney or Judge sitting an exam is not really relevant to a home assignment. If I was to call Feeney and ask his opinion on a point, I would be entitled to include this in my assignment (provided that it was correctly referenced).

Sean Bateman · 10-06-2011 09:45PM

Hope too many people aren't stressing right now either trying to finish their Part 2 assignment or upload it...

Sean Bateman · 11-06-2011 08:22AM

soft landing wrote: »

Working on Part 2 assignment myself. Finding it very hard to complete as on some of the topics you could write about them forever. Trying to keep the file note and letter as short as I can make it. I am a bit thrown by the first query from the client (residence, domicile & tax implications) and i have gone off on a bit of a tangent on it (it makes up about half of the file note), have gone through, patent exemption, High Earners Restriction for Cyril (even though im not sure if the questions are looking for this). Should be interesting to see what the model answer looks like!
Any ideas on the Maintenance issue? Is there anything to stop Marian getting (preference) shares in the UK company & remitting the dividends to a UK bank account (for when she moves home) thus avoiding Irish tax as she is on remittance basis?

Just my opinion, but I don't think that they were looking for much on the high earner restriction and patent exemption. All we know is that Cyril's UK company is trading and that Cyril patented a waste disposal device in the late 1990s. We can't assume that the Isle of Man dividends are Section 141 dividends. Finding out more info about the dividends and Cyril's companies is an action point but no more than that.

As for recommending alternative asset transfers, I wouldn't agree with that at all. The clients have decided what they want to do and want to know the tax consequences. It isn't appropriate for a tax adviser to start recommending the transfer of alternative assets, especially bringing a former spouse in as a shareholder.

Just my view and I could be off the wall. Good thing with these assignments is that there are many right answers.

mike2084 · 11-06-2011 05:00PM

Hi everybody,

I'm sure this has been asked before but is there anyway of looking at past exam papers other then becoming a student? I'm a CPA accountant looking at career options and would like to see if I'd be able for the questions. Thanks

Blooming · 13-06-2011 03:54PM

The results are due out Wednesday, just wondering if anyone knows will they be online after 12 tuesday night? Can't sleep properly for the last week in dread!

Legend100 · 13-06-2011 05:57PM

if i remember correctly, i think my part 2 results were up at round 8 in the morning last year

ascuteasabutton · 14-06-2011 08:56AM

Blooming wrote: »

The results are due out Wednesday, just wondering if anyone knows will they be online after 12 tuesday night? Can't sleep properly for the last week in dread!

I think its between 8am and 9am, thats the way it was last time.

Nervouspriest · 14-06-2011 08:29PM

Blooming wrote: »

The results are due out Wednesday, just wondering if anyone knows will they be online after 12 tuesday night? Can't sleep properly for the last week in dread!

You'd think the institute would have the times of the results up on their website at this stage.

I am awaiting two Part One exams. I am very nervous about tomorrow as the exams were very hard despite just being at Part One level..

Blooming · 14-06-2011 08:57PM

I am waiting for part 2, extremely nervous. I was hoping they would be up tonight but not long now:eek:.

Best of luck everyone.

Legend100 · 14-06-2011 09:02PM

Best of luck to all Part 1's & Parts 2's

I remember this time last year waking up to a hangover after seeing pearl jam at the O2 with the good news i passed the part 2!

ascuteasabutton · 14-06-2011 10:29PM

Nervouspriest wrote: »

You'd think the institute would have the times of the results up on their website at this stage.

I am awaiting two Part One exams. I am very nervous about tomorrow as the exams were very hard despite just being at Part One level..

It is on the website went up this evening results will be available online from 9am and we will also receive confirmation in the post!
Best of luck...i'm waiting for a Part 1 and also found it tough so you are not alone!

Blooming · 15-06-2011 08:29AM

Phew...passed:) hope everyone did great!!

Nervouspriest · 15-06-2011 08:30AM

Passed as well..

60% in PT and 50% in CGT Part One. Couldn't sleep last night.

ascuteasabutton · 15-06-2011 08:53AM

Passed too.....Part 2 exmas in August , study starts tonight!

Registered AITI Tax Qualification Info and Questions

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