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Deckton Ltd. is a large successful Canadian controlled private corporation (CCPC) operating in multiple jurisdictions through permanent establishments in which it carries on the business
Deckton Ltd. is a large successful Canadian controlled private corporation (CCPC) operating in multiple jurisdictions through permanent establishments in which it carries on the business of renovating residential homes. In 2020 Deckton's percentage of gross revenues and wages and salaries in each of the four jurisdictions in which they operate is as follows: Province Alberta British Columbia Saskatchewan U.S. Washington State Total Revenues 41% 20% 28% 11% 100% Wages 48% 23% 22% 7% 100% Average 44.5% 21.5% 25.0% 9.0% 100.0% Deckton's taxable income for 2020, which consists exclusively of active business income, is $2,447,000. Its Canadian operations account for $2,073,000 of its taxable income with the remainder of $374,000 attributable to its U.S. operations. The U.S. operations paid business and profits taxes in the amount of C$71,060. Deckton Ltd. represents the western Canadian operations of a corporate group composed of three companies, all of which are associated. Deckton is allocated $200,000 of the business limit of the associated group for 2020. The three companies all have taxation years ending December 31 with no short taxation years. The companies have been associated for over 10 years. All of the gross revenues of the three associated companies are derived from arm's length sales and there are no intercompany sales between them. The combined Adjusted Aggregate Investment Income (Adjusted All) of the associated group of companies is less than $50,000 in both 2019 and 2020. The Taxable Capital Employed in Canada (TCEC) of the associated group in 2019 was $14,125,000 and was $13,754,000 in 2020. Assume that Deckton's foreign tax credit is equal to the foreign taxes paid of $71,060. Required: Determine Deckton's minimum federal Part I Tax Payable for the year ending December 31, 2020. Show all supporting calculations. Deckton Ltd. is a large successful Canadian controlled private corporation (CCPC) operating in multiple jurisdictions through permanent establishments in which it carries on the business of renovating residential homes. In 2020 Deckton's percentage of gross revenues and wages and salaries in each of the four jurisdictions in which they operate is as follows: Province Alberta British Columbia Saskatchewan U.S. Washington State Total Revenues 41% 20% 28% 11% 100% Wages 48% 23% 22% 7% 100% Average 44.5% 21.5% 25.0% 9.0% 100.0% Deckton's taxable income for 2020, which consists exclusively of active business income, is $2,447,000. Its Canadian operations account for $2,073,000 of its taxable income with the remainder of $374,000 attributable to its U.S. operations. The U.S. operations paid business and profits taxes in the amount of C$71,060. Deckton Ltd. represents the western Canadian operations of a corporate group composed of three companies, all of which are associated. Deckton is allocated $200,000 of the business limit of the associated group for 2020. The three companies all have taxation years ending December 31 with no short taxation years. The companies have been associated for over 10 years. All of the gross revenues of the three associated companies are derived from arm's length sales and there are no intercompany sales between them. The combined Adjusted Aggregate Investment Income (Adjusted All) of the associated group of companies is less than $50,000 in both 2019 and 2020. The Taxable Capital Employed in Canada (TCEC) of the associated group in 2019 was $14,125,000 and was $13,754,000 in 2020. Assume that Deckton's foreign tax credit is equal to the foreign taxes paid of $71,060. Required: Determine Deckton's minimum federal Part I Tax Payable for the year ending December 31, 2020. Show all supporting calculations
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