Question
Mr. X is the only shareholder of X inc., a CCPC (Canadian-controlled private corporation). X inc. income has consistently been under the small business deduction
Mr. X is the only shareholder of X inc., a CCPC (Canadian-controlled private
corporation). X inc. income has consistently been under the small business deduction
(SBD) limit. X inc. has a capital dividend account of $80,000. Extra information provided:
Prior to the transactions
Paid-up capital (PUC) Adjusted cost base (ACB)
- Common shares ($1/share) 40,000 40,000
- Preferred shares ($1/share) 160,000 160,000
Assets (FMV) 2,300,000
Liabilities 1,100,000
Mr. X is deciding between different choices to get some cash from his corporation during the
tax year (20X1).
a) Payment by X inc. to Mr. X of a salary of $80,000.
b) Payment by X inc. to Mr. X of a non-eligible dividend of $80,000 on the common
shares. The amount is not paid from the capital dividend account.
c) X inc. will redeem 16,000 preferred shares to Mr. X at 5$/share for a total
payment of $80,000.
d) Payment by X inc. to Mr. X as a return of capital (PUC) of $80,000 for 1/2 the
preferred shares.
e) Payment by Ms. Y of $80,000 to Mr. X to purchase 20% (2,000 shares) of the
common shares of X inc.
f) Wind-up of X inc. and distribution of all the net funds available for distribution to Mr.
X. Assume the preferred shares already have been redeemed in a previous year and
doesn't exist anymore. Assume the assets to be 100% cash and no RDTOH for this option.
g) Payment by X inc. to Mr. X of a dividend of $80,000 on the common shares from
the capital dividend account.
Required:
For each option (which are all independent of each other), describe the tax consequences (effect on net income, effect on
taxable income, effect on tax payable, effect on paid-up capital, effect on adjusted cost base, if
applicable) with calculations during the year 20X1 for the shareholder (Mr. X), for the
corporation (X inc.) and the potential shareholder (Ms. Y). Specify if no tax impact.
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