Question 1: Darlene Saunders has carried on a business as a sole proprietor for over 10 years. The business has been very successful and has now reached a point where it is producing more income than she requires for her personal needs. Given this, she would like to incorporate the business to a new corporation, using the provisions of ITA 85(1). On January 5, 2023, the sale date, the tangible property of the business have total tax costs of $375,000. The combined FMV is $1,190,000 without goodwill. In addition, because of the success of the business, it is estimated that the business has goodwill the FMV of which is $320,000. At the transaction date, business liabilities are $115,000. The elected amount for the transfer will equal the tax costs of $375,000. The corporation will assume the $115,000 in business liabilities. In addition, Darlene will receive: • A promissory note of $85,000. • Preferred shares with a FMV of $100,000. • Common shares with a FMV of $1,210,000. Any taxable dividends paid by the corporation will be non-eligible. Required: Determine the following: 1. The ACB of each type of consideration received by Darlene. 2. The PUC of each class of shares issued as consideration by the new corporation. 3. The income tax consequences to Darlene if the new preferred shares are redeemed at their FMV. (15 marks)
Question 1: Darlene Saunders has carried on a business as a sole proprietor for over 10 years. The business has been very successful and has now reached a point where it is producing more income than she requires for her personal needs. Given this, she would like to incorporate the business to a new corporation, using the provisions of ITA 85(1). On January 5, 2023, the sale date, the tangible property of the business have total tax costs of $375,000. The combined FMV is $1,190,000 without goodwill. In addition, because of the success of the business, it is estimated that the business has goodwill the FMV of which is $320,000. At the transaction date, business liabilities are $115,000. The elected amount for the transfer will equal the tax costs of $375,000. The corporation will assume the $115,000 in business liabilities. In addition, Darlene will receive: • A promissory note of $85,000. • Preferred shares with a FMV of $100,000. • Common shares with a FMV of $1,210,000. Any taxable dividends paid by the corporation will be non-eligible. Required: Determine the following: 1. The ACB of each type of consideration received by Darlene. 2. The PUC of each class of shares issued as consideration by the new corporation. 3. The income tax consequences to Darlene if the new preferred shares are redeemed at their FMV. (15 marks)
Chapter20: Income Taxation Of Trusts And Estates
Section: Chapter Questions
Problem 8DQ
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Transcribed Image Text:Question 1: Darlene Saunders has carried on a business as a sole proprietor for over 10 years. The
business has been very successful and has now reached a point where it is producing more income than
she requires for her personal needs. Given this, she would like to incorporate the business to a new
corporation, using the provisions of ITA 85(1).
On January 5, 2023, the sale date, the tangible property of the business have total tax costs of $375,000.
The combined FMV is $1,190,000 without goodwill. In addition, because of the success of the business, it
is estimated that the business has goodwill the FMV of which is $320,000. At the transaction date,
business liabilities are $115,000.
The elected amount for the transfer will equal the tax costs of $375,000. The corporation will assume the
$115,000 in business liabilities. In addition, Darlene will receive:
• A promissory note of $85,000.
• Preferred shares with a FMV of $100,000.
• Common shares with a FMV of $1,210,000.
Any taxable dividends paid by the corporation will be non-eligible.
Required: Determine the following:
1. The ACB of each type of consideration received by Darlene.
2. The PUC of each class of shares issued as consideration by the new corporation.
3. The income tax consequences to Darlene if the new preferred shares are redeemed at their FMV. (15
marks)
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