Registered AITI Tax Qualification Info and Questions

Legend100

Oops am i missing something re the branch and profit remittances.

pg 185 of the manual says there is no concept of a dividend for the branch

ie the branch profits in the uk are added to the total irish profits of TBL and overall profits taxed at 12.5% with credit for UK tax paid in relation to branch profits

if there was a "dividend" between the branch and TBl then the same profits would be taxed twice in Ireland so this cannot happen

Please say i have this right as it was one of my main points!!!!

And i thought there would be UK witholding tax on the dividend remitted under the Ireland/UK treaty?

Pinkypod007

heffelump wrote: »

ok i think im ready to start typing but i was just wondering is the general opinion that we should form a subsidiary, suffer the losses in yrs one and two and carry forward for offset in year 3. Sell the company and claim 626b?
would the main reason for not using a branch be the admin?

And on the interest borrow through irish company claiming 247 on the full amount as the interest deduction would be of no benefit because we're selling the uk sub at the end of the day?

I have gone with the branch. As they plan on selling after year 3, I have taken advantage of the losses and utilised them in TBL. The DTA credit covers the chargeable gain on the sale of the branch....

Legend100

Finally finished...!! worst effort ever

littlelady81

Hey are you giving much detail in the step plan?? What sort? I know its only 5. Marks but every little helps!!! :cool:

gallyer

I ended up going with a branch and an asset sale, think its the most efficient way to do it from an Irish perspective. Could be totally wrong, was a toss of a coin between the two options to be honest! What did everyone else decide in the end?

A quick proof read and i'll send it in then!!

Good luck everyone!

gingerhousewife

Just submitted it, not really happy with it and still questioning my own decisions but I think the best thing now is to forget about it and concentrate on PT exam! Good luck everyone

ramacc

gingerhousewife wrote: »

Just submitted it, not really happy with it and still questioning my own decisions but I think the best thing now is to forget about it and concentrate on PT exam! Good luck everyone

What approach are you taking to the PT are you doing the furhter reading as outlined in the manuals, what approach are people taking to the course generally i.e. is anyione studying the pre reading or just the actual manuals

garytm

Will the base cost of the shares be nil in a share sale and the base cost of the assets be their cost? so would it not make much more sense to sell assets?

gingerhousewife

ramacc wrote: »

What approach are you taking to the PT are you doing the furhter reading as outlined in the manuals, what approach are people taking to the course generally i.e. is anyione studying the pre reading or just the actual manuals

I'd say just the manuals for this one, and lots of exam questions. Hopefully will pick up on other things such as revenue material etc through exam questions.

Legend100

my step plan was pure sh*te. It was three pages but i would be surprised if i got any of the five marks

i went with sub mainly due to 626b but didnt include much calculations so my argument was pretty weak, submitting it now, thank god it is over!

bubblicious

I ended up going with the branch first and then transferring to a sub.

Set up HoldCo, transfer shares from TBL into HoldCo. Set up branch and utilise losses for 2 years. A third party sets up a new company and HoldCo transfers branch in to NewCo in exchange for shares in NewCo. (S. 615 because they're unrelated, S.587 as a share-for-share exchange, S80 SDCA for SD), hold for 2 years and then dispose under S.626B. No clawback of S.80 SDCA as shares held for 2 years.

Or am I completely off the mark?!!!

TheScriptFan

gingerhousewife wrote: »

I'd say just the manuals for this one, and lots of exam questions. Hopefully will pick up on other things such as revenue material etc through exam questions.

I am doing just the manuals also - but if the manual refers to a specific tax briefing etc i am taking them in also. Does everyone think the exam will be the same format as last year despite not being open book?
I.E. likely a secondment??

ascuteasabutton

Just wondering has anyone received confirmation that their Home Assignment was received,I still haven't gotten offical confirmation(we were meant to get an email)...getting kind of worried!

gingerhousewife

ascuteasabutton wrote: »

Just wondering has anyone received confirmation that their Home Assignment was received,I still haven't gotten offical confirmation(we were meant to get an email)...getting kind of worried!

Just got mine last night. They updated the website on Monday to say we should receive them in the week beginning 17/01/11 so I'd say if you don't get it by Friday get on to them.

ascuteasabutton

Cheers for that just had another look there and they seem to have updated it since yesterday to say we will receive it by close of business today so hopefully it comes by then

TheScriptFan

Just wondering, does anyone know can we bring stamp duty and CAT act in with us tomorrow? Might not be needed, but has been referred to in the sample answers. What do you ye think?

Legend100

Well im assuming that we can since we can in the summer and there was a CAT question on last yrs july paper so im bringing them. Just noticed aswel that the DTA for CAT for UK and US are in the CAT book which is handy as id say that if there is a CAT question, it wll be on them

ramacc

Legend100 wrote: »

Well im assuming that we can since we can in the summer and there was a CAT question on last yrs july paper so im bringing them. Just noticed aswel that the DTA for CAT for UK and US are in the CAT book which is handy as id say that if there is a CAT question, it wll be on them

Did anyone else find the interim assignment very long?

Legend100

way too long!!!

failed the crap out of it id say, spent way too much time on the very first question so didnt even answer 60% of the paper, my own fault really. but it was too long, there is no way you could give a good answer in each part within an hour and a half

Marz66

Hi all

I agree it was very long. The only good thing is they kept the same format as last year and as the sample paper. They could have screwed us with a whole paper on share options or pensions or something. It said on last years exam report that they took timing into account so hopefully they will do that again this year

gingerhousewife

I found it very long too, especially the first part. Was happy that the content was ok, and there was no curve ball thrown in, but really could have done with another hour maybe to give a comprehensive answer. Was disappointed that even though it was acknowledged in last year's examiners report that students didn't have enough time, they didn't make it shorter this year. If anything I'd say it was longer.

ascuteasabutton

Just wondering how people are coming along with study as exams are only 2 months away???

Struggling to get really into it at the moment and i'm hoping I am not alone

TheScriptFan

ascuteasabutton wrote: »

Just wondering how people are coming along with study as exams are only 2 months away???

Struggling to get really into it at the moment and i'm hoping I am not alone

Well it's really 3 months until Part 3 exams...phew!!
I am going slowly, trying to go over all the Part 2 material and get my reading up-to-date which is proving seriously time consuming. How much study leave does everyone have? I think I will just have from Easter onwards, about 3 weeks. Am trying to get a strategy together of writing very concise notes of main points from Part 2's...have most of the notes still from last year and then doing notes from part 3's..reading some tax briefings as I go and looking at past papers. I don't like the notes they give us in class, don't really find them too helpful to be honest. But I read them just incase!! Definitely need to ramp up my study, have given myself 1st March deadline to get really focused, so just tipping along until then, probably just putting in about 4 hours a week at the mo!

Legend100

TheScriptFan wrote: »

probably just putting in about 4 hours a week at the mo!

That's four hours more than me!! must get down to it soon, doing them on my own back so have no study leave and will have to take holidays (and possibly unpaid leave) to sit them


Think i really need to start tabbing all the legislation in detail very soon as that took ages during the part 2 so don't wana spend study time doing that when the exams are coming up quickly

......must say im dreading personal tax!

ascuteasabutton

I'm probably doing around the same 4-8 hours....Is there anyone out there that is finding the lectures more a waste of precious time than if you spent the 2 days studying at the weekend, if you know what I mean? I'm finding it to be alot of reading from slides/books that could easily be done at home!

TheScriptFan

Hi Part 3's,

Just wondering what approach everyone is taking to studying? Saturday has given me a right kick up the arse that I needed and I've realized if I want to get all 4 first go, I need to put some serious time in - starting now!!
1) Is it best to go through all the material first, and then start the past papers? This is what the VAT guy suggested on Sat.
2) How far off the book do I need to go, extra reading etc. Do I need to be looking at the various tax briefs etc?
3) Study leave - How much Study leave do people recommend? I don't want to take too long, or too short.

Any other tips, study methods that anyone would like to share would be awesome...I know I have the time now, and the motivation to get stuck in and get them all out of the way, so I want to make sure I keep focused and don't slack off and leave it to the last minute (like I normally do!!)

Tks, TSC

ramacc

At this stage looks like i'll be cramming with 4 weeks study leave.

Working overtime in evenings and weekends and am in Jersey so don't make lectures ekkk :mad:

Anyone know whne the CA reuslts are out?

TheScriptFan

ramacc wrote: »

At this stage looks like i'll be cramming with 4 weeks study leave.

Working overtime in evenings and weekends and am in Jersey so don't make lectures ekkk :mad:

Anyone know whne the CA reuslts are out?

Results are due out on Fri I believe.

Gosh that's very difficult, I can PM you with any tips for they give over the next couple of weeks. I must say I found Sat lectures very helpful. The VAT lecturer is really excellent.

Best of luck! You'll be grand with 4 wks study leave.

ramacc

Hi Script,

That would be much appreciated cheers!

TheScriptFan

ramacc wrote: »

Hi Script,

That would be much appreciated cheers!

How did everyone get on with the CA?? I did very well on the assignment, and failed the exam miserably