Question
Stan is the sole shareholder of Hardware Ltd. Hardware purchased all of the shares of Tools Inc. in 20x4 for $500,000. Tools incurred a non-capital
Stan is the sole shareholder of Hardware Ltd. Hardware purchased all of the shares of Tools Inc. in 20x4 for $500,000. Tools incurred a non-capital loss of $25,000 in the year ended December 31, 20x3. Stan has decided to initiate a Section 88 wind-up of Tools Inc. into Hardware Ltd. on June 23, 20x7. Due to the seasonal nature of his sales, Stan would like to maintain the April 30th year end that he has used since beginning his business. Stan's accountant has prepared the following balance sheet for Tools Inc. as of June 22, 20x7. The fair market value of the assets on both June 22, 20x7 and the date of acquisition in 20x4 are presented in the following table:
| Balance Sheet June 22, 20x7 (Cost) | FMV June 22, 20X7 | FMV 20X4 |
Shares in Pub Co. | $25,000 | $80,000 | $70,000 |
Accounts Receivable (net of $2,000 for doubtful accounts) | $18,000 | $18,000 |
|
Land | $125,000 | $500,000 | $300,000 |
Building (UCC) | $100,000 | $300,000 | $210,000 |
Total Assets | $268,000 |
|
|
Bank Loan | $70,000 |
|
|
Common shares | $10,000 |
|
|
Retained earnings | $188,000 |
|
|
Total shareholders equity and liabilities | $268,000 |
|
|
Tools paid dividends of $8,000 to Hardware in 20x7. Required: Answer the following questions pertaining to the wind-up of Tools Inc. into Hardware Ltd.: 1) Hardware will be deemed to have acquired the following assets of Tools at what values?
Shares in Pub Co. | $ |
Accounts receivable | $ |
Land | $ |
Building | $ |
2) Calculate the value of the section 88(1)(d) "bump" available on the ACB for the non-depreciable capital property. 3) Identify the assets which may use the bump, and the amount of the bump available for each asset identified. Also identify any unusable bump amount. 4) When will Hardware Ltd. be able to use the non-capital loss from Tools Inc.
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