Question 2 (20 marks)

Bob Best owned 100,000 shares of ABC Ltd., a publicly-traded Canadian corporation. These shares, including brokerage fees, were acquired at a cost of $600,000. Based on current trading values, these shares are now worth $900,000.

The following four cases make different assumptions as to the identity of the purchaser, the circumstances of the sale, and the proceeds of disposition. In each case, assume that the purchaser immediately resold the shares for their fair market value of $900,000.

Case 1:

Bob Best sold the shares to his brother for $200,000 to create a loss, since Bob Best had realized significant capital gains during the current year. Since his brother had no other source of income, Bobs brother would be taxed on the gain from the resale at the minimum federal rate.

Case 2:

Bob Bests mother had realized a large amount of capital gains during the current year. To help his mother, Bob Best sold the shares to her for $1,800,000. Bobs mother planned to use the loss on the immediate resale to offset her capital gains.

Case 3:

Because Bob Best needed funds to acquire a house for his grandmother, he sold the shares to an arms length party for $900,000.

Case 4:

Bob Best gifted the shares to his 17-year-old daughter.

Required:

For each of the cases, advise Bob Best of the tax consequences that will result from the disposition, and indicate the tax consequences to the purchaser of the shares when they are resold. In addition, in Cases 1 and 2, indicate whether the stated tax planning objective was achieved.

this question is from Canadian tax principle value 1 Chapter 8