Question
Bruce 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
Bruce 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 2018 for $500,000. Bruce has decided to initiate a Section 88 (of Income Tax Act) wind-up of Small-Ltd. into Big-Ltd. on September 01, 2020.
Bruce's accountant has prepared the following balance sheet for Small-Ltd. as of August 31, 2020. The Fair Market Value (FMV) of the assets on both August 31, 2020 and the date of acquisition in 2018 are presented in the following table:
| Balance Sheet Aug 31, 2020 [Cost] | Aug 31, 2020 [FMV] | 2018 [FMV] |
Shares in a Public Corporations | $ 25,000 | $ 80,000 | $ 70,000 |
Accounts Receivable (net of $2,000 in doubtful accounts) | 18,000 | 18,000 |
|
Land | 125,000 | 500,000 | 300,000 |
Building ( *UCC) | 100,000* | 300,000 | 210,000 |
Total Assets | 268,000 |
|
|
Bank Loan | 70,000 |
|
|
Common shares | 10,000 |
|
|
Retained earnings | 188,000 |
|
|
Total liabilities | 268,000 |
|
|
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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