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Assignment Problem Nineteen - 1 (Property Transfer To And From A Trust) Each of the following independent Cases involve transfers of property to trusts by a settlor for no consideration. Three of the Cases also involve capital distributions from trusts to capital beneficiaries. A. A gift of non-depreciable capital property is made to a qualifying spousal inter vivos trust. The adjusted cost base of the property to the settlor was $45,700. At the time of the transfer the fair market value of the property is $51,000. At a later point in time, the property is transferred to the spouse. At this time the fair market value of the property is $49,200. B. A gift of depreciable capital property (a rare violin) is made to an inter vivos trust in favour of the settlor's adult children. The capital cost of the violin to the settlor, a world renowned violinist, was $125,000. On the date of the gift, the UCC was $72,000 and the fair market value was $155,000. C. A transfer of a piece of vacant land is made to a qualifying spousal testamentary trust. The cost of the land for the deceased spouse was $200,000, and the fair market value on the date of the transfer to the trust is $225,500. At the time of his death, the decedent had a large net capital loss carry forward of $78,000. | D. A depreciable property is transferred to an inter vivos trust in favour of the settlor's adult children. The capital cost of the property is $17,600 and its UCC is $9,100. It is the last asset in its class. At the time of the transfer, the fair market value of the property is $5,000 E. A gift of non-depreciable capital property is made to an inter vivos trust in favour of the settlor's adult children. The adjusted cost base of the property to the settlor was $36,900. Its fair market value on the date of the gift is $40,200. At a later point in time, when the fair market value of the property is $51,700, the property is transferred to the children. F. A non-depreciable capital property is transferred to an alter ego trust. The cost of the capital property to the settlor was $101,500. On the date of the transfer, the estimated fair market value is $92,300. At a later point in time, when the estimated fair market value of the property has increased to $100,000, the property is transferred back to the settlor. Required: For each Case indicate: 1. The tax consequences to the settlor that result from the transfer of the property to the trust assuming the transfer price is chosen to optimize the tax position of the settlor. 2. The tax value(s) for the transferred property that will be recorded by the trust. 3. In those cases where property is transferred to a beneficiary, the tax consequences to the trust and the tax value(s) that will be recorded by the beneficiary. Assignment Problem Nineteen - 1 (Property Transfer To And From A Trust) Each of the following independent Cases involve transfers of property to trusts by a settlor for no consideration. Three of the Cases also involve capital distributions from trusts to capital beneficiaries. A. A gift of non-depreciable capital property is made to a qualifying spousal inter vivos trust. The adjusted cost base of the property to the settlor was $45,700. At the time of the transfer the fair market value of the property is $51,000. At a later point in time, the property is transferred to the spouse. At this time the fair market value of the property is $49,200. B. A gift of depreciable capital property (a rare violin) is made to an inter vivos trust in favour of the settlor's adult children. The capital cost of the violin to the settlor, a world renowned violinist, was $125,000. On the date of the gift, the UCC was $72,000 and the fair market value was $155,000. C. A transfer of a piece of vacant land is made to a qualifying spousal testamentary trust. The cost of the land for the deceased spouse was $200,000, and the fair market value on the date of the transfer to the trust is $225,500. At the time of his death, the decedent had a large net capital loss carry forward of $78,000. | D. A depreciable property is transferred to an inter vivos trust in favour of the settlor's adult children. The capital cost of the property is $17,600 and its UCC is $9,100. It is the last asset in its class. At the time of the transfer, the fair market value of the property is $5,000 E. A gift of non-depreciable capital property is made to an inter vivos trust in favour of the settlor's adult children. The adjusted cost base of the property to the settlor was $36,900. Its fair market value on the date of the gift is $40,200. At a later point in time, when the fair market value of the property is $51,700, the property is transferred to the children. F. A non-depreciable capital property is transferred to an alter ego trust. The cost of the capital property to the settlor was $101,500. On the date of the transfer, the estimated fair market value is $92,300. At a later point in time, when the estimated fair market value of the property has increased to $100,000, the property is transferred back to the settlor. Required: For each Case indicate: 1. The tax consequences to the settlor that result from the transfer of the property to the trust assuming the transfer price is chosen to optimize the tax position of the settlor. 2. The tax value(s) for the transferred property that will be recorded by the trust. 3. In those cases where property is transferred to a beneficiary, the tax consequences to the trust and the tax value(s) that will be recorded by the beneficiary