Question
Ms. Carlton is a Canadian resident for tax purposes and the sole shareholder of C-Ltd. She transfers three assets she owns to C-Ltd. in exchange
Ms. Carlton is a Canadian resident for tax purposes and the sole shareholder of C-Ltd. She transfers three assets she owns to C-Ltd. in exchange for cash and preferred shares (P/S) of C-Ltd. Ms. Carlton needs your help to defer the maximum income possible for tax purposes on the transfer of the assets. Ms. Carlton has already received the cash payment as shown below in the table. Ms. Carlton and C-Ltd. will jointly make a Section 85 elections (Roll-over) for each of the asset based on your recommendation. The Fair market value (FMV), Adjusted cost base (ACB), Undepreciated capital cost (UCC), and cash received on the transfers are as follows:
Type of Asset | FMV of Assets ($) | ACB ($) | UCC ($) | Cash Received ($) |
Land | 325,000 | 100,000 | N/A | 80,000 |
Building | 625,000 | 375,000 | 275,000 | 300,000 |
Requried:
A. For each of the three assets individually, determine the following:
1) Elected Amount (Agreed Amount) 2) Fair Market Value of preferred shares 3) Paid-up capital of preferred shares 4) Income for Ms. Carlton, if any
(You can provide your response using the letter references below):
Type of Asset | Elected Amount ($) | FMV of P/S ($) | PUC of P/S ($) | Income for Ms. Carlton, if any ($) |
Land | (a) | (b) | (c) | (d) |
Building | (e) | (f) | (g) | (h) |
B. List common uses of Sec.85 Roll-over elections (provide 3 situations). (Cannot use the details in this question as one of your responses)
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