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For many years, Janice Virtue had been a professor of Business Ethics in the Faculty of Business at a major Canadian university. In 2019, while

For many years, Janice Virtue had been a professor of Business Ethics in the Faculty of Business at a major Canadian university. In 2019, while continuing to teach one section of Business Ethics, she incorporated Virtue Ltd. (VL), a CCPC, in order to market her numerous publications and online courses involving the application of ethical principles to business situations. While the company experienced a net operating loss of $128,000 in the fiscal period ending December 31, 2019, VL experienced rapidly increasing sales during 2020. Because Janice believed the improvement was indicative of the success to come, VL moved to larger premises that were purchased for $423,000. Of this total, $100,000 related to the land, with the remaining $323,000 allocated to the building. Because the building was to be used exclusively for non- residential purposes, the necessary election was made with the CRA to allocate the building to a separate Class 1. In selling the previous premises in 2020, VL realized an allowable capital loss on the land of $36,000. The building was sold at its UCC value. The Net Income of VL for the year ending December 31, 2020, after deducting CCA on the Class 1 building, was $16,000. VL realized no capital gains during the year. In May 2021, Janice decided it was time to see the world and retire early. Given these circumstances, Janice decides to sell her VL shares. She finds an unrelated corporate buyer who is willing to acquire the shares on June 1, 2021. This buyer is a large publicly traded Canadian company. VL properties include the copyrights to all of her publications. The corporate buyer believes its marketing team will be able to return the company to profitability within a relatively short period of time. By May 2020, Janice's lawyer indicated that it is likely that she will be convicted on multiple charges and will spend a significant amount of time in prison. She has also been advised by her employer that her contract to teach Business Ethics will not be renewed in the fall. As this acquisition of control resulted in a deemed year end, VL prepared an Income Statement for the period January 1, 2020, through May 31, 2021. A business loss of $34,000 is reported for the taxation year ending May 31, 2021, as a result of the acquisition of control. There were, however, no further capital losses. On May 31, 2021, the values of the company's assets were as follows: Asset Cost UCC Fair Market Value Temporary Investments 32,000 N/A 7,000 Accounts Receivable 123,000 N/A 110,000 Land 100,000 N/A 115,000 Building 323,000 313,310 352,000 Equipment 46,000 33,120 5,000 Vehicles (Class 10) 36,000 21,420 25,000 Copyrights Nil Nil 42,000 VL will make all possible elections to minimize any net capital and non-capital loss balances. Shortly after taking over VL, the corporate buyer decided that some of the extra space in VL's facilities could be used for manufacturing electronic reading devices. VL's income (loss) from the two separate businesses for the period June 1 through December 31, 2021, and for the 2022 taxa- tion year was as follows: Business June 1 to Dec. 31, 2021 2022 Year Electronic Reading Devices 123,000 (26,000) Janice's Publications (53,000) 185,000 Required: a. Indicate any non-capital and net capital loss balance that are tainted as a result of the acquisition of control. b. Indicate the maximum amount of the non-capital loss carry forward that can be claimed for the taxation year June 1 through December 31, 2021. c. Indicate the maximum amount of the non-capital loss remaining that can be claimed for the 2022 taxation year.

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