Exam 12: Organization, Capital Structures, and Income Distributions of Corporations

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Which of the following scenarios would be appropriate for a section 85 rollover?

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Calamari Inc.has transferred the following three assets to Squid Co., a Canadian controlled private corporation, under section 85 of the Income Tax Act. Building Land Goodwill Adjusted cost base (ACB) \ 230,000 \ 70,000 NI Fair market value \ 220,000 \ 150,000 \ 50,000 Undepreciated capital cost (UCC) \ 120,000 N/A NIL Sale price \ 220,000 \ 150,000 \ 50,000 Cash received \ 100,000 \ 100,000 NIL Shares received \ 120,000 \ 50,000 \ 50,000 Required: Determine the following amounts: A) The minimum amount that Calamari may elect to transfer each asset in the rollover based on the information provided B) Calamari's income or loss for tax purposes as a result of the rollover C) The ACB of the shares received by Calamari following the rollover D) The PUC of the shares received by Calamari following the rollover

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 A.  B.  C.  D.  Minimum  Calamari’s  ACB of  PUC of  elected value  income or loss  Calamari’s shares  Calamari’s shares  Building $120,000NIL$20,000$20,000 Land $100,000$15,000NILNIL Goodwill $1$0.50$1$1\begin{array}{|l|r|r|r|r|}\hline& \text { A. } & \text { B. } & \text { C. } & \text { D. } \\\hline&\text { Minimum } &\text { Calamari's } &\text { ACB of }&\text { PUC of } \\&\text { elected value }&\text { income or loss }&\text { Calamari's shares }&\text { Calamari's shares }\\\hline \text { Building } & \$ 120,000 & \mathrm{NIL} & \$ 20,000 & \$ 20,000 \\\hline \text { Land } & \$ 100,000 & \$ 15,000 & \mathrm{NIL} & \mathrm{NIL} \\\hline \text { Goodwill } & \$ 1 & \$ 0.50 & \$ 1 & \$ 1 \\\hline\end{array}

A shareholder of a Canadian corporation is planning to transfer a building to the corporation and wishes to avoid tax on the transaction.The building originally cost $150,000.It has a UCC of $85,000 and a fair market value of $225,000.Which of the following will meet the taxpayer's wish?

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C

Which of the following statements is TRUE regarding the disposal of shares by a shareholder?

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There are significant attributes in the tax treatment of shareholder debt and shareholder equity from the perspective of both the CCPC and the shareholders. Required: List one tax consequences for each of the following: 1) Return on investment - shareholder debt 2) Loss on investment - shareholder debt 3) Return of capital - shareholder debt 4) Return on investment - shareholder equity 5) Loss on investment - shareholder equity 6) Return of capital - shareholder equity

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The following shares were issued in Barney Co.between 2018 and 2020: January 1, 2018: Kelsey Weber incorporated Barney Co.and received 2,000 common shares for $2,000 from the corporate treasury. January 1, 2019: István Horvath received 500 common shares in Barney Co.for $1,000 (fair market value) from the corporate treasury. December 31, 2020: Addison Walker received 1000 preferred shares of Barney Co.for $5,000 (fair market value) from the corporate treasury. Required: A.Calculate the paid-up capital (PUC) of the common shares and the preferred shares of Barney Co.at the end of 2020. B.Calculate the PUC and adjusted cost base (ACB) of the shares held by Kelsey, István, and Addison. (Work must be shown for marks to be awarded.)

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Salamander Co.transferred a small piece of land to one of its shareholders as a dividend in kind.The land originally cost $50,000 and had a fair market value of $175,000 at the time of the transfer.The corporation will realize ________, and the shareholder will realize ________.

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Makeda Kemal has operated a proprietorship for five years and has decided to incorporate the company this year.The following assets will be transferred to the corporation: UCC/ACB FMV Land \ 50,000 \ 200,000 Building (capital cost \ 120,000) 100,000 140,000 Equipment (capital cost \ 100,000) 75,000 75,000 Goodwill NIL 20,000 The transfer will also include the company's inventory and accounts receivables.The inventory originally cost $25,000 and has a fair market value of $30,000.The accounts receivable have a fair market value of $10,000 and a cost of $12,000. Makeda wishes to minimize the tax effect of this business decision using a Section 85 rollover where beneficial.Makeda will receive the maximum non-share consideration possible and the remainder of the transfer in preferred shares for assets transferred using Section 85.Any other assets will be transferred for non-share consideration. Required: A.What is the elected value for each of the assets transferred under Section 85? B.What is the value of the non-share consideration that Makeda will receive for those assets benefitting from Section 85? (Show the amounts for each asset, and the total for all.) C.What is the value of the preferred shares that Makeda must receive in order to defer any income inclusions from the assets that will benefit from Section 85? (Show the amounts for each asset, and the total for all.) D.Identify any asset(s) not included in your previous answers, and briefly explain why they were excluded.(< 20 words per asset) E.If Makeda elects to transfer the accounts receivable using a Section 22 election, what is the amount of Makeda's business loss that will be included in the corporation's income? (Work must be shown for marks to be awarded.)

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Little Co.is a Canadian controlled private corporation and Large Co.is a public Canadian corporation.Both corporations have a paid-up capital balance of $25,000.Which of these statements is TRUE, provided the proper legal steps are followed?

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Jules Mart'nez sold 5000 shares back to ABC Co.for $25,000 during the current fiscal year.Jules purchased these shares from Evrim Malas three years ago for $15,000.Evrim had originally purchased the shares from the corporate treasury for $10,000.Which of the following tax consequences will Jules recognize?

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Mika Collin has operated a proprietorship for three years, and now plans to incorporate the company.All of the assets and liabilities of the company will be transferred to the corporation. Amongst the list of assets being transferred are accounts receivable with a fair market value of $5,000 and a cost of $7,000.If Mika chooses to transfer the receivables using a joint Section 22 election, which of the follow will apply?

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