Candy Holdings Pte Ltd ("Candy") is a Singapore incorporated investment holding company. It is in the business of making investments and its rental income, derived through its various property holdings, is assessed under Section 10E of the Income Tax Act. It also has an 80% shareholding in Chocolate N' Spice Pte Ltd ("CNS"), a Singapore incorporated and tax resident company. Candy's shareholders are Taza Choc Inc. ("Taza"), a public listed company tax resident in Country Y and Best Beans Pte Ltd ("Best Beans), a private limited company tax resident in Singapore. Taza has not been the subject of any takeover or merger since its incorporation and Richard, an Indonesian citizen, has been the sole shareholder of Best Beans since its incorporation. The group structure of Candy is as follows: Taza (Country Y) Best Beans (Singapore) 35% Candy (Singapore) 80% Chocolate N' Spice ("CNS") (Singapore) 65% All the companies in Singapore have a 31 October year end and there have not been any changes to their respective business activities. In addition, the tax position of the various Singapore companies apart from Candy are as follows: Year of Assessment 2017: Unabsorbed trade loss Year of Assessment 2018: Statutory income Year of Assessment 2019: Statutory income Year of Assessment 2020: Adjusted (loss)/profit Capital allowances Best Beans CNS ($30,000) $90,000 $130,000 ($180,000) $540,000 Deferred ($180,000) For the year ended 31 October 2019, Candy's Profit and Loss Account is as follows: Rental income Interest income earned on deposits with Singapore approved banks Less: Operating expenses for rental business (including depreciation of $65,000) Cash donation to institution of public character Net loss for the year $ 1,050,000 46,000 1,096,000 1,150,000 25,000 (79,000) Candy is entitled to capital allowances of $20,000 for Year of Assessment 2020. Required: (a) Compute the loss items of Candy for the Year of Assessment 2020. (b) (5 marks) Evaluate how each of the loss items of Candy and Best Beans arising in the Year of Assessment 2020 may be utilised. Your answer should address the following: All relevant conditions under the various options discussed. With respect to the shareholdings test, the minimum % shareholding threshold should be addressed and where applicable, determine the relevant shareholding comparison dates and who the relevant shareholders are. Address how the conditions are met or not. The amounts that may be carried back or transferred under group relief where these options are considered. For group relief, you should also address who the transferor and transferee parties are. (20 marks)