Question
PART B = A couple of years ago, on 1 August 2021, Hilton Enterprises Pty Ltd, acquired all of the shares in another company CorpCo
PART B = A couple of years ago, on 1 August 2021, Hilton Enterprises Pty Ltd, acquired all of the shares in another company CorpCo Pty Ltd. (Eight years earlier CorpCo Pty Ltd had acquired two acres of land in the Central Coast. The purchase price of the land was $1 million. At the time of the purchase of the land, the minutes of the directors meetings recorded that the purpose of the purchase was to build single-storey beach villas for holiday rental to tenants. However, the work never actually began on the construction of beach villas.) Hilton Enterprises Pty Ltd, in determining a purchase price for the shares in CorpCo Pty Ltd, valued the Central Coast land at $1 million. CorpCo Pty Ltd's previous business activities have not involved residential construction projects. Following the purchase of the shares in CorpCo Pty Ltd, new directors were appointed to CorpCo Pty Ltd. The new directors passed a resolution to seek a rezoning of the Central Coast land, aiming to construct 8 homes on the land and to sell each home at a profit. CorpCo Pty Ltd submitted a rezoning application to the council which involved the payment of council fees of $5000 and also legal fees of $4000 in relation to obtaining legal assistance in the preparation of the rezoning application. The rezoning application by CorpCo Pty Ltd was successful. Following the rezoning CorpCo Pty Ltd obtained an estimate of the market value of the Central Coast land. The valuation of the land was $3 million. In January 2022 CorpCo Pty Ltd commenced work on the building of the homes. On 1 March 2023 the building of the homes was completed at a total cost of $2 million. There was significant market demand for the homes and CorpCo Pty Ltd sold each home for $2 million. Advise on any relevant income tax and/or capital gains tax implications, regarding the sale of property arising from the facts in PART B. In your answer make sure you show your calculation of any relevant amount included in CorpCo's assessable income in relation to the sale of property.
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