Sheila Solo is the sole shareholder of Eastern Small Wares Ltd., a Canadian-controlled private corporation based in southwestern Ontario. The company wholesales small wares to retail variety stores in eastern Canada. Two years ago, ESL purchased 60% of the common shares of Byron Products Ltd., a company in a similar line of business but operating in western Canada. The remaining 40% of BPLs shares are owned by Ramjet Dillon. Dillon is actively involved in managing BPLs operations. The companys internal accountant has prepared the year-end financial statements according to GAAP (see Exhibit I).

Tax assignments in attachment