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( Comprehensive Corporate Tax Payable ) Falko Ltd . is a Canadian controlled private corporation with a December 3 1 year end. For its year

(Comprehensive Corporate Tax Payable)
Falko Ltd. is a Canadian controlled private corporation with a December 31 year end. For its year
ending December 31,2020, its accounting Net Income Before Taxes, as determined using gen-
erally accepted accounting principles, was $1,029,700. Relevant information for the 2020 year
necessary to make the appropriate reconciliation adjustments to Net Income For Tax Purposes,
Taxable Income, and federal Taxes payable is as follows.
Falko's amortization expense was $494,500. Maximum deductible CCA for the year was
$713,000. Company policy has always been to deduct the maximum available CCA.
The company's revenues included foreign source investment income of C$44,000. The amount
received, however, was only C$36,080 as a result of foreign withholding income taxes of 18
percent, or $7,920. The company only recorded the amount received as revenue.
Falko sold one of its buildings that required costly renovations in favour of leasing a building.
The total sales price was $1,725,000 with $500,000 allocated to the land and $1,225,000 to
the building. The original cost of the land and therefore its adjusted cost base was $650,000.
The capital cost and adjusted cost base of the building was $1,000,000 and its UCC at the
time of sale was $885,000. For accounting purposes the net book value of the building was
$710,000. The company records accounting gains and accounting losses based on the net
book value for the building and the original cost of the land.
During the year, the company earned the following amounts of Canadian source investment
income, all of which have been included in net income for accounting purposes:
Interest On Long Term Investments
$28,700
Non-Eligible Dividends From A 100% Owned Subsidiary ,77,500
Eligible Dividends On Bank of Nova Scotia Shares
53,300
Falko is only associated with one company - its wholly owned subsidiary Lands Inc. after
acquiring all of its shares in 2016. Lands received a dividend refund of $26,475 as a result
of the dividends paid to Falko in 2020. Since Lands' non-eligible RDTOH was insufficient
to recover all of the dividend refund it was forced to partially rely upon its eligible RDTOH.
Lands' GRIP account balance was nil at year end, preventing it from designating any of the
dividends paid to Falko as eligible. Of the dividend refund, 43 percent was attributable to its
eligible RDTOH and 57 percent to its non-eligible RDTOH.
Company expenses for accounting purposes included (1) $39,800 spent on business meals
and entertainment; (2) a write-down of inventory (for obsolescence) beyond that permitted
in valuing inventory for tax purposes; the excess amount is $11,400; (3) life insurance
premiums totaling $14,375 paid on the life of two of the principal shareholders; and
(4) bonuses to the same two shareholders for $75,000 each. The bonuses were never paid.
Falko's active business income for the year was $796,400, which includes $427,000 of
Canadian manufacturing profits that qualify for the M&P deduction (ITA 125.1). Since the
company operates in a province that provides a special rate for M&P profits, the company
calculates the federal M&P deduction every year.
During the year ending December 31,2020, the company used its existing cash resources
to pay taxable dividends of $285,000. It is the policy of the company to only designate divi-
dends as eligible to the extent they generate a dividend refund.
At December 31,2019, Falko had an eligible RDTOH balance of $19,446, a non-
eligible RDTOH balance of $73,670, and a GRIP balance of $24,000. During 2019, Falko
paid taxable dividends of $118,800,$18,800 of which were designated as eligible. As a
result of paying the dividends, Falko received a dividend refund of
($118,800) of the dividend refund ($18,800)(381?3%) was attributable to the
eligible RDTOH and the remainder of $38,333[($100,000)(381?3%)] was attributable to
its non-eligible RDTOH.
The combined Adjusted Aggregate Investment Income for the two associated corp
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