Question
Ms. Debbie Gaudette has operated her unincorporated business for a number of years.The tangible assets of this business have a FMV of $1,000,000 and a
Ms. Debbie Gaudette has operated her unincorporated business for a number of years.The tangible assets of this business
have a FMV of $1,000,000 and a tax cost of $200,000.In addition, as the business has been extremely profitable, she
estimates that the business has goodwill of $75,000. The total liabilities of the business amount to $0. As she no longer
needs all of the income that the business is producing, she would like to transfer the business to a new CCPC and, in order
to defer taxation, she would like to use the provisions of ITA 85 for the transfer. She will make the transfer at an elected
value of $200,000.The corporation will issue a $25,000 cheque to Ms. Gaudette.Other consideration will be made up of
redeemable preferred shares with a fair market value of $50,000 and common shares with a fair market value of
$950,000.Any dividends will be eligible (38% gross-up).
Required: Determine all the following in the boxes provided:
A. The range of elected values (minimum and maximum would be: (1 mark)
B. How much of the elected value will be allocated to the ACB of the preferred shares and ACB of the common
shares: (2 marks)
C. Calculate the PUC of both the common shaes and preferred shares: (2 marks)
D. The tax consequences of the preferred stock redemption would be as follows: (2 marks)
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