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Also explain why the section applies Assignment Problem Fourteen - 4 (Associated Companies) Each of the following is an independent Case involving the ownership of

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Also explain why the section applies

Assignment Problem Fourteen - 4 (Associated Companies) Each of the following is an independent Case involving the ownership of voting shares of Canadian controlled private corporations. All of the corporations have taxation years that end on December 31 and have only one class of shares. A. Mr. Bond owns 55 percent of Sarnen Inc. Sarnen Inc. owns 40 percent of Barxo Ltd. Mr. Bond also owns 14 percent of Hax Ltd., which in turn owns 54 percent of the shares of Barxo Ltd. Mr. Bond's 10 year old daughter owns 6 percent of the shares of Barxo Ltd. B. Mr. Jones, Mr. Knight, and Mr. Long are three unrelated individuals. Mr. Jones owns 50 percent of the shares of Anix Inc. and 25 percent of the shares of Brex Ltd. Mr. Knight owns 50 percent of the shares of Brex Ltd. Mr. Long owns 50 percent of the shares of Anix Inc. and 25 percent of the shares of Brex Ltd. C. Sam Scully owns 60 percent of Scully Inc. His sister, Susan Wilson, owns 80 percent of Wilson Ltd. and 30 percent of Scully Inc. Sam Scully also owns 10 percent of Wilson Ltd. D. Joan and Sarah Lartch are sisters. Joan owns 100 percent of the shares of JL Inc. and 31 percent of the shares of Meadow Ltd. Her sister Sarah owns 60 percent of the shares of SL Inc., with the remaining 40 percent of the shares held by her mother. Sarah also owns 39 percent of the shares of Meadow Ltd. The remaining shares of Meadow Ltd. are held by an unrelated party. E. John and May Carp each own 30 percent of the shares of Jomay Inc. Serge and Beth Carp each own 45 percent of the shares of Besa Ltd. John and Serge Carp are brothers. Beth Carp owns 40 percent of the shares of Jomay Inc. and May Carp owns 10 percent of the shares of Besa Ltd. Required: For each of the preceding Cases, determine whether the corporations are associ- ated. Support your conclusions with references to specific provisions of ITA 256. In order to assist you in answering this question, we have provided you with the content of ITA 256(1). ITA 256(1) Associated corporations For the purposes of this Act, one corporation is associated with another in a taxation year if, at any time in the year, (a) one of the corporations controlled, directly or indirectly in any manner whatever, the other; (b) both of the corporations were controlled, directly or indirectly in any manner what- ever, by the same person or group of persons; (c) each of the corporations was controlled, directly or indirectly in any manner what- ever, by a person and the person who so controlled one of the corporations was related to the person who so controlled the other, and either of those persons owned, in respect of each corporation, not less than 25% of the issued shares of any class, other than a specified class, of the capital stock thereof; (d) one of the corporations was controlled, directly or indirectly in any manner whatever, by a person and that person was related to each member of a group of persons that so controlled the other corporation, and that person owned, in respect of the other corporation, not less than 25% of the issued shares of any class, other than a specified class, of the capital stock thereof; or (e) each of the corporations was controlled, directly or indirectly in any manner what- a related group and each of the members of one of the related groups was related to all of the members of the other related group, and one or more persons who were members of both related groups, either alone or together, owned, in respect of each corporation, not less than 25% of the issued shares of any class, other than a specified class, of the capital stock thereof. Assignment Problem Fourteen - 4 (Associated Companies) Each of the following is an independent Case involving the ownership of voting shares of Canadian controlled private corporations. All of the corporations have taxation years that end on December 31 and have only one class of shares. A. Mr. Bond owns 55 percent of Sarnen Inc. Sarnen Inc. owns 40 percent of Barxo Ltd. Mr. Bond also owns 14 percent of Hax Ltd., which in turn owns 54 percent of the shares of Barxo Ltd. Mr. Bond's 10 year old daughter owns 6 percent of the shares of Barxo Ltd. B. Mr. Jones, Mr. Knight, and Mr. Long are three unrelated individuals. Mr. Jones owns 50 percent of the shares of Anix Inc. and 25 percent of the shares of Brex Ltd. Mr. Knight owns 50 percent of the shares of Brex Ltd. Mr. Long owns 50 percent of the shares of Anix Inc. and 25 percent of the shares of Brex Ltd. C. Sam Scully owns 60 percent of Scully Inc. His sister, Susan Wilson, owns 80 percent of Wilson Ltd. and 30 percent of Scully Inc. Sam Scully also owns 10 percent of Wilson Ltd. D. Joan and Sarah Lartch are sisters. Joan owns 100 percent of the shares of JL Inc. and 31 percent of the shares of Meadow Ltd. Her sister Sarah owns 60 percent of the shares of SL Inc., with the remaining 40 percent of the shares held by her mother. Sarah also owns 39 percent of the shares of Meadow Ltd. The remaining shares of Meadow Ltd. are held by an unrelated party. E. John and May Carp each own 30 percent of the shares of Jomay Inc. Serge and Beth Carp each own 45 percent of the shares of Besa Ltd. John and Serge Carp are brothers. Beth Carp owns 40 percent of the shares of Jomay Inc. and May Carp owns 10 percent of the shares of Besa Ltd. Required: For each of the preceding Cases, determine whether the corporations are associ- ated. Support your conclusions with references to specific provisions of ITA 256. In order to assist you in answering this question, we have provided you with the content of ITA 256(1). ITA 256(1) Associated corporations For the purposes of this Act, one corporation is associated with another in a taxation year if, at any time in the year, (a) one of the corporations controlled, directly or indirectly in any manner whatever, the other; (b) both of the corporations were controlled, directly or indirectly in any manner what- ever, by the same person or group of persons; (c) each of the corporations was controlled, directly or indirectly in any manner what- ever, by a person and the person who so controlled one of the corporations was related to the person who so controlled the other, and either of those persons owned, in respect of each corporation, not less than 25% of the issued shares of any class, other than a specified class, of the capital stock thereof; (d) one of the corporations was controlled, directly or indirectly in any manner whatever, by a person and that person was related to each member of a group of persons that so controlled the other corporation, and that person owned, in respect of the other corporation, not less than 25% of the issued shares of any class, other than a specified class, of the capital stock thereof; or (e) each of the corporations was controlled, directly or indirectly in any manner what- a related group and each of the members of one of the related groups was related to all of the members of the other related group, and one or more persons who were members of both related groups, either alone or together, owned, in respect of each corporation, not less than 25% of the issued shares of any class, other than a specified class, of the capital stock thereof

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