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Problem 5 M s . Bast owns all the common shares o f Batterup L t d . , a Canadian - controlled private corporation,

Problem 5
Ms. Bast owns all the common shares of Batterup Ltd., a Canadian-controlled private corporation,
which started operations in2009. Batterup Ltd. has been quite profitable in recent years. As a result, Three-Strikes Ltd., a Canadian public corporation, has offered Ms. Bast $2,525,000 for the assets,excluding cash, asat December 31,2023. The offer price reflects unrecorded goodwill of $475,000.Ms. Bast wants to wind up the company after the sale of the assets.
The pro forma balance sheet of Batterup Ltd.as
at December 31,2023,isas follows:
Cost UCC FMV
Assets
Cash $25,000
Account Receivable(net)87,500 $75,000
Inventory 222,500155,000
Land 110,000-450,000
Building 350,000 $75,000950,000
Equipment 450,000220,000100,000
Marketable securities142,500-320,000
1,387,500 $2,050,000
Liabilities
Current Liabilities $540,000
Future income taxes 50,000
Shareholder's Equity
Share Capital(PUC)100,000
Retained earnings 697,500
Total liabilities and equity $1,387,500
Additional Information
(1) Batterup Ltd. pays corporate tax atan overall combined rate of13%on active business income
eligible for the small business deduction, 27%on active business income not eligible for the small
business deduction, and an initial 40% rate for investment income, plus the 10%3% additional refundable
tax on investment income. The corporation has a GRIP balance of zero.
(2) The reserve for doubtful accounts at December 31,2023 was $15,000.
(3) Batterup Ltd. and Three-Strikes Ltd. elected under section 22.
(4) The company has a capital dividend account balance of $40,000. You have agreed todo the
following for Ms. Bast:
(A) Compute the amount available for distribution to the shareholder.
(B) Determine the components of the distribution to the shareholder.
(C) Compute the taxable capital gain or allowable capital loss on the disposition ofMs. Bast's
shares on the winding-up.(Assume the adjusted cost base ofMs. Bast's common shares is
$100,000.)
(D) Explain the conditions for and advantages of using a section 22 election.
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