Question
Alexis is the sole shareholder of Big-Ltd. which has a fiscal year end of December 31 st . Big-Ltd. purchased all of the shares of
Alexis is the sole shareholder of Big-Ltd. which has a fiscal year end of December 31st. Big-Ltd. purchased all of the shares of Small-Ltd. in 2016 for $500,000. Alexis has decided to initiate a Section 88 (of Income Tax Act) wind-up of Small-Ltd. into Big-Ltd. on September 01, 2019. Alexis's accountant has prepared the following balance sheet for Small-Ltd. as of August 31, 2019. The Fair Market Value (FMV) of the assets on both August 31, 2019 and the date of acquisition in 2016 are presented in the following table:
Small-Ltd. did not pay any dividends to Big-Ltd. during these years. Required: 1) Determine the amounts for the following assets that Big-Ltd. will report, immediately following the windup, before Bump allocations? a) Shares in Public Corporations b) Accounts receivable c) Land d) Building 2) Calculate the value of the section 88(1)(d) of Income Tax Act 'bump available for Big-Ltd. 3) Identify the asset(s) which may use the bump, and the amount of the 'bump' available for the asset(s) identified. |
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