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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
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 $1,215,000. The sale was effective September 30, 2021. In the 2021 taxation year, the business broke even for tax purposes. The following was the balance sheet for ABC with the fair market value (FMV) of assets as indicated in the photos included:
dditional Information: The tax values of all assets are identical to amounts for book purposes, except for the building and equipment and the intangibles. The following pertains to these assets: The intangibles consist of a client list that was acquired in 2019. The fair market value of the client list is \\( \\$ 120,000 \\). The fair market value of goodwill is \\( \\$ 68,000 \\). As of the balance sheet date, the non-eligible RDTOH balance for the company is \\( \\$ 13,000 \\). The CDA balance is \\( \\$ 12,000 \\). 3. \\( \\quad \\mathrm{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 \102/3 additional refundable tax on investment income. ABC has a GRIP balance of NIL at September 30, 2022. 4. \\( \\quad A B C \\) and the purchaser elected under section 22 with respect to the accounts receivable. 5. The cost of the \\( A B C \\) shares to \\( M r \\). A was \\( \\$ 1,000 \\). Required: (a) Compute the amount available for distribution (i.e., computation of tax consequents to \\( \\mathrm{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. dditional Information: 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: 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 \\). As of the balance sheet date, the non-eligible RDTOH balance for the company is \\( \\$ 13,000 \\). The CDA balance is \\( \\$ 12,000 \\). 3. \\( \\quad \\mathrm{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 \102/3 additional refundable tax on investment income. ABC has a GRIP balance of NIL at September 30, 2022. 4. \\( \\quad A B C \\) and the purchaser elected under section 22 with respect to the accounts receivable. 5. The cost of the \\( A B C \\) shares to \\( M r \\). A was \\( \\$ 1,000 \\). Required: (a) Compute the amount available for distribution (i.e., computation of tax consequents to \\( \\mathrm{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
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