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Several years ago, Ms . Jennifer Bond acquired a business location that included land and a building for a total of $ 9 5 0

Several years ago, Ms. Jennifer Bond acquired a business location that included land and a building for a total of $950,000. At the time, it was estimated that the FMV of the land was $220,000 and the FMV of the building was $730,000.
Ms. Bond carried on the business for several years as a sole proprietor and, during this period, CCA was claimed on the building. As there were years in which she experienced losses, she did not always claim the maximum amount of CCA.
Ms. Bond has agreed to take your advice and incorporate the business. She will use ITA 85(1) to sell the land and building to the new corporation in January of 2023. At the time of the sale, the building had a UCC of $625,000. Other relevant amounts were as follows:
Elected
Property Tax Cost FMV Amount
Land $220,000 $ 510,000 $220,000
Building 625,000980,000730,000
Total $845,000 $1,490,000 $950,000
There is a $400,000 mortgage on the property that will be assumed by the new corporation. In addition, the new corporation will issue a $500,000 promissory note to Ms. Bond. The remaining consideration will be in the form of common shares with a FMV and legal capital of $590,000. The new corporation does not have a balance in its GRIP account in any of the taxation years under consideration.
Required:
A. What are the income tax consequences of making this sale at an elected amount of $950,000? Your answer should include amounts to be included in Ms. Bond's income as a result of the sale, as well as the corporation's tax costs for the land and building.
B. Compute the ACB of the consideration that Ms. Bond has received from the corporation.
C. Compute the PUC of the common share consideration.
D. What amounts would be included in Ms. Bond's 2023 net income if, in 2023, she sells the common shares for $650,000?

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