Question
Question 3 John Titor is the owner-manager of SERN Inc., an R&D consulting firm. He purchased all of his outstanding shares from his older sister,
Question 3
John Titor is the owner-manager of SERN Inc., an R&D consulting firm. He purchased all of his outstanding shares from his older sister, Christina, for $25,000. The paid-up capital of these shares were $30,000, equal to the initial amount Christina invested into the corporation.
On January 1st 2022, John decided to sell SERN Incs business to a third party through an asset sale. The buyer will purchase all of SERN Incs assets at FMV, plus an additional $15,000. After the sale closes, John will redeem the companys shares for the remaining cash in the company, and wind-up the company afterwards.
SERN Inc.s balance sheet on January 1st 2022 contains the following assets, and has $25,000 of liabilities:
Asset | Tax Costs | FMV |
Inventory | $7,000 | $10,000 |
Marketable Securities | $25,000 | $20,000 |
Land | $80,000 | $120,000 |
Building (Original Cost: $60,000) | $30,000 (UCC) | $50,000 |
Furniture (Original Cost: $12,000) | $4,000 (UCC) | $2,000 |
Total: | $202,000 |
The company has the following account balances as of January 1st 2022 (prior to any proposed sales):
Account | Balance |
Capital dividend account | $8,000 |
Non-eligible RDTOH | $3,000 |
GRIP balance | $10,000 |
SERN Incs corporate tax rates are 12% for active business income, and 49.67% for aggregate investment income.
After retiring from the business, John got involved in a partnership with a group of friends. He received a 10% stake in Reading Steiner LLP, which operates multiple bookstores across the country, in exchange for helping to manage the business. After the first year of operations, John withdrew $16,000 from the partnership. The partnerships net income for the year was $240,000, consisting of $150,000 of business income, $70,000 of capital gains, and $20,000 of non-eligible dividends.
John has $28,000 of net capital loss carry-forwards available to him for the 2022 tax year.
REQUIRED
Calculate the total tax payable (federal and provincial combined) that John will incur on the transactions above, assuming a 45% marginal tax rate. Assume that the dividend tax credit is equal to the gross-up.
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