Learning Outcomes addressed and assessed in this Assignment:  Demonstrate an understanding of the Irish taxation system in relation to capital gains tax  Select and apply appropriate reliefs and exemptions to Capital Gains any tax computations Marking Scheme: Client Query 1 40% Client Query 2 25% Client Query 3 25% Presentation and referencing Total 10% Tax Assignment You are a Taxation Senior in a Big 4 Accountancy Firm. The Partner in charge of your department has approached you and asked you to write a professional report for Partner review providing Taxation advice for the following client issues: A) Tom Murphy Tom Murphy purchased a house in Kilkenny as his principal private residence on 1 June 1969 for €5,000. He lived in this house until 31 May 1979 when he moved to Dublin as part of a job promotion. He lived in Dublin until 30 September 1984, when he moved to the London, again for a job promotion. He stayed there until 31 August 1990, after which, he decided to take a career break and travel to Australia. He returned to Ireland on 1 December 1993 and immediately moved back into his house in Kilkenny. He then remained there until 31 January 2014, when he moved to Galway. He sold the house in Kilkenny on 31 May 2016 for €550,000. The house was valued at €9,000 on 6 April 1974. Tom Murphy has approached the firm requesting taxation advice in relation to his Capital Gains Tax obligation. B) Crawford Limited Crawford Limited is an Irish tax resident company and owns 100% of the ordinary share capital of both Jousset Sarl and Murad SA. Jousset Sarl is a trading company and is tax resident in France whilst Murad SA is a trading company and is tax resident in Tunisia. Crawford Limited has owned the ordinary share capital of Jousset Sarl for 10 years and Murad SA for 5 years. Crawford Limited has received an offer from BigCorp Plc for the entire issued share capital of both Jousset Sarl and Murad SA. These potential sales would generate capital gains for Crawford Limited of €3,000,000 (Jousset Sarl) and €2,000,000 (Murad SA). The directors of Crawford Limited have approached the firm requesting taxation advice in relation to these two potential divestments. C) Michael O’Sullivan Michael O’Sullivan has approached the firm requesting taxation advice in relation to the Entrepreneur Relief introduced in Finance Act 2013. He is aware that some changes were made in Budget 2017 in relation to this relief and he would like clarification on what exactly this relief is and in what circumstances it applies. Requirement: The professional report should address the three issues above individually. You are required to provide the following in relation to each of the issues raised Tom Murphy 1. Calculate Tom Murphy’s Capital Gains Tax liability, if any, which arises on the sale of his house in 2016, ensuring all qualifying Capital Gains Tax reliefs/exemptions are utilised. Detail all conditions which must be satisfied for any relief that is claimed. (35 marks) 2. State when the Capital Gains Tax, if any, is payable. (5 marks) Crawford Limited 1. Discuss the main features of the relief for the disposal of shares in a subsidiary and detail the conditions which must be satisfied in order for this relief to apply. (10 marks) 2. Advise Crawford Limited on any potential Capital Gains Tax liabilities which would arise on the sale of the shares. (10 marks) 3. State when the Capital Gains Tax, if any, is payable. (5 marks) Michael O’Sullivan 1. Discuss the main features of the Entrepreneur relief, detailing all conditions which must be satisfied in order for the relief to apply and any exclusions which apply. (15 marks) 2. Detail the changes that were introduced in Budget 2017 and outline when these changes will come into effect. (10 marks) 10 marks will be awarded for presentation and referencing