Mr Brown was seconded from a US parent company and employed by a subsidiary in Hong Kong as Sales Director of Far East Region under a two-year contract commencing 1 January 2020. Under the terms of employment, Mr Brown was required to travel to different places to perform his duties. He stayed the following places during the years of assessment 2020/21 and 2021/22: He received the following income during the years of assessment 2020/21 and 2021/22: 7) On 15 October 2020, Mr Brown was granted an option at a cost of $10,000 which entitled him to take up 100,000 shares at $1 each in one of his employer's subsidiary companies. The market price of the shares was $5 each. On 1 May 2021, Mr Brown exercised the option when the market price of the shares was $3 each. On 1 September 2021, Mr Brown sold these shares at a price of $1.5 each. Notes: (1) The allowance was granted for travelling expenses between home and office. Mr Brown only spent 2/3 of the allowance for such purpose. (2) Mr Brown spent $40,000 and $90,000 on overseas travelling during his vacation leave in the years of assessment 2020/21 and 2021/22 respectively. (3) Upon completion of the contract, Mr Brown was entitled to contract gratuity of $360,000. The contract gratuity was only received by Mr Brown on 31 January 2022. After completion of the contract, Mr Brown signed another employment contract immediately and continued to work with the employer. (4) During the period 1 January 2020 to 30 June 2020, his employer provided Mr Brown a place of residence in a hotel suite consisting of one bedroom. Mr Brown had paid monthly service charge of $1,000 to the hotel. From 1 July 2020, Mr Brown had rented a flat for his accommodation at a monthly rent of $22,000. His employer reimbursed part of the rent to him on production of rental receipts. Mr Brown elected to spread back the contract gratuity. Required: a. Compute the assessable income of Mr Brown for the years of assessment 2020/21 and 2021/22 after taking into account the contract gratuity being related back. b. Advise Mr Brown: (i) what types of lump sum income can be spread back under the Inland Revenue Ordinance; (ii) application procedure and time limit for spreading back of such lump sum income. Mr Brown was seconded from a US parent company and employed by a subsidiary in Hong Kong as Sales Director of Far East Region under a two-year contract commencing 1 January 2020. Under the terms of employment, Mr Brown was required to travel to different places to perform his duties. He stayed the following places during the years of assessment 2020/21 and 2021/22: He received the following income during the years of assessment 2020/21 and 2021/22: 7) On 15 October 2020, Mr Brown was granted an option at a cost of $10,000 which entitled him to take up 100,000 shares at $1 each in one of his employer's subsidiary companies. The market price of the shares was $5 each. On 1 May 2021, Mr Brown exercised the option when the market price of the shares was $3 each. On 1 September 2021, Mr Brown sold these shares at a price of $1.5 each. Notes: (1) The allowance was granted for travelling expenses between home and office. Mr Brown only spent 2/3 of the allowance for such purpose. (2) Mr Brown spent $40,000 and $90,000 on overseas travelling during his vacation leave in the years of assessment 2020/21 and 2021/22 respectively. (3) Upon completion of the contract, Mr Brown was entitled to contract gratuity of $360,000. The contract gratuity was only received by Mr Brown on 31 January 2022. After completion of the contract, Mr Brown signed another employment contract immediately and continued to work with the employer. (4) During the period 1 January 2020 to 30 June 2020, his employer provided Mr Brown a place of residence in a hotel suite consisting of one bedroom. Mr Brown had paid monthly service charge of $1,000 to the hotel. From 1 July 2020, Mr Brown had rented a flat for his accommodation at a monthly rent of $22,000. His employer reimbursed part of the rent to him on production of rental receipts. Mr Brown elected to spread back the contract gratuity. Required: a. Compute the assessable income of Mr Brown for the years of assessment 2020/21 and 2021/22 after taking into account the contract gratuity being related back. b. Advise Mr Brown: (i) what types of lump sum income can be spread back under the Inland Revenue Ordinance; (ii) application procedure and time limit for spreading back of such lump sum income