Q. No. 3- X Ltd. owns all of the shares of Y Ltd. The shares of Y have an adjusted cost base of $40,000 and a fair market value of $940,000. Y has retained earnings of $100,000 (earned after 1971) and no eligible or non-eligible refundable dividend tax on hand. Y plans to pay a dividend of $900,000 to X. Subsequently, X will sell the shares of Y Ltd. to an arm's-length person for $40,000.

SWFT Comprehensive Volume 2019
42nd Edition
ISBN:9780357233306
Author:Maloney
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Chapter20: Corporations: Distributions In Complete Liquidation And An Overview Of Reorganizations
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Q. No. 3 - X Ltd. owns all of the shares of Y Ltd. The shares of Y
have an adjusted cost base of $40,000 and a fair market value of
$940,000. Y has retained earnings of $100,000 (earned after
1971) and no eligible or non-eligible refundable dividend tax on
hand. Y plans to pay a dividend of $900,000 to X. Subsequently,
X will sell the shares of Y Ltd. to an arm's-length person for
$40,000.
Determine the tax consequences to X Ltd. of these transactions.
Transcribed Image Text:Q. No. 3 - X Ltd. owns all of the shares of Y Ltd. The shares of Y have an adjusted cost base of $40,000 and a fair market value of $940,000. Y has retained earnings of $100,000 (earned after 1971) and no eligible or non-eligible refundable dividend tax on hand. Y plans to pay a dividend of $900,000 to X. Subsequently, X will sell the shares of Y Ltd. to an arm's-length person for $40,000. Determine the tax consequences to X Ltd. of these transactions.
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