J. Tilkenhurst Limited (JTL) is a Canadian-controlled private corporation which was started in 1988 by Mr. Santosh Prasad with an initial investment in common shares of $18,000. Mr. Prasad has decided that it's time to retire and move to his retirement home in Saskatoon, Saskatchewan. Therefore, Mr. Prasad wishes to wind up JTL.
The following is a projected tax balance sheet prior to the sale and distribution of the assets as at the intended date of the winding-up:

Additional Information
(1) The corporation is taxable at a total 20% corporate tax rate for the first $400,000 of active business income and an initial 40% rate for all other income, plus the 62/3% additional refundable tax on investment income. The corporation has a GRIP balance of nil.
(2)

The customer lists were acquired in 2002 from a similar business which was acquired that year. The balance in the CEC account includes the maximum cumulative eligible capital amounts in each year.
(3) The books of account do not reflect unrecorded goodwill with an estimated fair market value of $60,000. This is in addition to the customer lists.
(4) The accounts receivable are to be sold to a factoring company.
REQUIRED
Prepare an analysis of the income tax implications of the winding-up.

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J. Tilkenhurst Limited BALANCE SHEET as at December 31, 2008 as RDTOH Accounts receivable $15,000 6,000 S 60,000 5.000 55,000 110,000 26,000 85,000 23,000 10,000 accounts Inventory Marketable securities Building-UCC Equipment-UCC Customer list CE C account balance 350,600 Liabilities Future income taxes Common shares (PUC). Capital dividend account (no unabsorbed negative amounts). S 45,000 41,000 18,000 12,000 234,600 Other surplus Assets Accounts receivable Inventory Marketable securities. Land Building Equipment Customer lists* Cost FMV S 60,000 S 52,000 110,000 12.000 26.000 85,000150,000 66,000 97,000 6,000 42,453 70,000 26,000 30,000