Homework Assignment 3

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Langara College *

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TAXATION

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Accounting

Date

Apr 3, 2024

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docx

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2

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Homework Assignment #3 AP 14-2, 14-5 (Case A and B), 14-7 (Part D(i)) AP 14-2 (Acquisition of Control Rules) Boudin Inc. was incorporated 10 years ago in New Brunswick. On incorporation, all of the shares were issued to Andre Boudin. The company carried on a business of distributing health food prod- ucts throughout the Maritime provinces. The company has always used a December 31 taxation year end. The company operated successfully for a number of years. However, late in 2019, increased com- petition resulted in a steep decline in the sales of Boudin Inc. Because of this the company reported a business loss of $42,000 in 2020 and $123,000 in 2021. In addition, the company realized an allowable capital loss of $32,000 in 2021 as a result of the disposition of some temporary investments. There were no capital gains realized in 2021. In early 2022, seeing no real hope for a return to profitable operations, Mr. Boudin begins a search for a buyer for his company’s shares. On May 1, 2022, all of the shares are sold to Healthy Bites Ltd., a manufacturer of health food products. This company hopes to be able to reverse the for tunes of Boudin Inc. Mr. Boudin is not related to the individuals who control Healthy Bites Ltd. For the short taxation year of January 1, 2022, to April 30, 2022, resulting from the AOC, Boudin Inc. reported a business loss of $48,000. The reported business loss includes a write-down of inventories to their FMV as required by ITA 10(1) on April 30, 2022, and a bad debt deduction for doubtful accounts receivables, as a result of the application of ITA 111(5.3). On April 30, 2022, Boudin Inc. owned the following properties with the following tax attributes: Property Cost ucc FMV Long-term investments* $ 47000 N/A $ 82,000 Land 207,000 N/A 305,000 Building 465,000 $360,000 485,000 Equipment 350,000 190,000 150,000 *Healthy Bites intends to sell the investments as soon as possible. Required: A. Indicate any non-capital and net capital loss balances that are tainted as a result of the AOC. Assume the company will elect to trigger any eligible capital gains or recapture using FMV as the elected amount for property with accrued but unrealized gains (ITA 111(4)(e)). B. If Healthy Bites Ltd. decides to only use the election(s) required to offset non-capital and net capital losses that would become tainted as a result of the AOC, indicate the properties on which the elections should be made and the amounts that should be elected. C. Advise Healthy Bites Ltd. as to the recommended course of action (Part A or B). AP 14-5 (Investment Tax Credits) Case A In 2022, Lumina Ltd., a CCPC with a December 31 taxation year end, hired 18 eligible appren- tices—six were hired at the beginning of January, six more August 1, and the remaining six November 1. Each of the apprentices began with an annual salary of $45,000, all of which qualified for the apprenticeship tax credit. Based on the hiring dates, the first group of six each earned $45,000 for the year while the second group each earned $18,750 and the third group each earned $7500. The total amount paid to these individuals in 2022 is $427,500. Lumina Ltd. also acquired new class 53 machinery for $640,000 on November 27, 2022. This equip- ment is to be used in New Brunswick. The machinery was delivered to the company site in early December and was put into use immediately. The machinery is qualified property for investment tax credit purposes. Required: Describe the 2022 and 2023 income tax consequences of the salary and wages paid to apprentices and the purchase of the class 53 machinery. Specifically, determine whether the amounts qualify for any investment tax credit and, if so, the amount of that tax credit and the 2023 implications of claiming any available tax credit in 2022. Assume that the company will claim the maximum CCA possible on the class 53 machinery in 2022, that the opening UCC in class 53 for 2022 is nil, that no additions will be made to the class in 2023, and that the company will have suf- ficient Part 1 income tax to fully use any investment tax credits in 2022.
Case B Taurus Ltd., a CCPC with a December 31 taxation year end, has been conducting scientific research and experimental development (SRED), which qualifies for additional federal investment tax credit incentives based on its “SRED expenditure limit.” Taurus has never been associated with another corporation since its incorporation in 2016. The company has provided the following information for its 2021 and 2022 taxation years: 2021 2022 Taxable income $ 735,000 $ 850,000 TCEC 16,900,000 21,440,000 Required: Determine Taurus's SRED expenditure limit for its 2022 taxation year. AP 14-7 (Corporate Surplus Distributions) Grado Ltd. is a CCPC with a December 31 taxation year end. The company was incorporated in 2013. All of the existing shareholders are individuals. The company’s condensed balance sheet, prepared in accordance with generally accepted accounting principles (ASPE), as of December 31, 2021, is as follows: Total assets $858,000 Current liabilities $122,000 Long-term liabilities 384,000 Shareholders’ equity: 700 preferred Class A (paid-up capital) $ 14,000 1,000 common shares (paid-up capital) 87,000 Retained earnings 251,000 352,000 Total equities $858,000 Required: Determine the income tax consequences of each of the following independent trans- actions. Income tax consequences are considered to include the amount of taxable dividends, the dividend tax credit, any taxable capital gains and allowable capital losses, and any changes to the ACB of the relevant property and the paid-up capital (PUC) of a class of shares. Assume that any dividends paid or deemed to be paid by Grado Ltd. would be non-eligible. D. (i) Mrs.Wiebe owns 100 of the common shares. She purchased the shares for $18 a share in 2014.The company redeems these shares for $90 per share in June 2022.
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