Sundown Inc. is a CCPC. After disposing of all of its properties and paying all of its liabilities (except corporate income tax), Sundown Inc. is left with cash of $3,054,500. The Company must still file and pay its final corporate income tax return, which currently shows a combined federal & provincial income tax payable of $200,000. The PUC of the Company's shares is $290,400. After the sale of all of its properties, the Company has a Non-Eligible RDTOH account balance of $155,100, a CDA balance of $85,800, and a GRIP balance of nil. The individual shareholder of Sundown Inc. owns 100% of the Company’s shares, with an ACB of $100,000.

Determine the income tax consequences to the shareholder of Sundown Inc. if, in 2021, the Company makes the maximum cash distribution to its shareholder on the winding-up of the corporation. Assume that appropriate elections will be made to minimize any income tax to the shareholder. While you are not required to calculate income tax payable for the shareholder, you must indicate the amount and type of income that the shareholder will have to include in net income for tax purposes and indicate the amount and type of any related tax credits for the shareholder.