Your client, Mr. A, a Canadian resident, owned all of the issued shares of ABC Ltd., which carries on an electrical service business. The taxation year-end of the corporation was September 30. On your advice, he agreed to sell all of the assets of the company (except the cash) to one purchaser for $1,215,000. The sale was effective September 30, 2021. In the 2021 taxation year, the business broke even for tax purposes. The following was the balance sheet for ABC with the fair market value (FMV) of assets as indicated

ABC Ltd. BALANCE SHEET As at September 30, 2022 Assets FMV Current: Cash $ 74,000 Marketable securities 25,000 S 15,000 Accounts receivable (See Appendix I) S 176,000 Less: reserve for doubtful debts 6,000 170,000 172,000 Inventories, at cost 230 000 240,000 S 499,000 Property and plant Land, at cost 60,000 110,000 Buildings & equipment, at cost (Note 1) $ 750,000 Less accumulated amortization 290,000 460,000 490,000 Intangibles, at cost (Note 1) S 100,000 Less accumulated amortization 57,500 42,500 188,000 $1,061,500 $1,215,000 Liabilities & Shareholder's Equity Current liabilities S 208,000 Future income taxes 20,000 Shareholder's equity Common share capital Authorized 50,000 shares Issued 1,000 shares S 1,000 Retained earnings (Note 2) 832,500 833 500 $1,061,500 Additional Information: 1. The tax values of all assets are identical to amounts for book purposes, except for the building and equipment and the intangibles. The following pertains to these assets: Cost UCC FMV Building $600,000 $304,000 $423,000 Equipment 150,000 76 000 67 000 $750,000 $380 000 $490,000 Intangibles Class 14.1 100,000 88,000 188,000 The intangibles consist of a client list that was acquired in 2019. The fair market value of the client list is $120,000. The fair market value of goodwill is $68,000. 2. As of the balance sheet date, the non-eligible RDTOH balance for the company is $13,000. The CDA balance is $12,000. 3. ABC pays corporate tax at a 13% rate on active business income eligible for the small business deduction and at a 40% rate on any other income, before the 1023% additional refundable tax on investment income. ABC has a GRIP balance of NIL at September 30, 2022. 4. ABC and the purchaser elected under section 22 with respect to the accounts receivable. 5. The cost of the ABC shares to Mr. A was $1,000. Required: (a) Compute the amount available for distribution (i.e., computation of tax consequents to ABC and After-tax funds available for distribution) to Mr. A on the sale of assets. (b) Determine the components of the distribution to Mr. A on a winding-up of the corporation