Brewers Ltd$.$ is a CCPC with a calendar$-$based December $31$ taxation year end. The company was

incorporated in $2018$ by four unrelated individuals, Ayan, Spencer, Seda, and Pablo, all of whom

$($with the exception of Pablo$)$ met in university while working toward their master$$s of business

administration $($MBA$).$ They quickly realized that their business ideas were quite similar and agreed

to work together to carry on a new business. Spencer recommended they speak with a friend of

his, Pablo, who had a degree in chemical engineering. Together the four individuals came up with

the idea to operate their own micro$-$breweries. Pablo created unique mixtures that have been used

to produce very successful beers in three provinces with strong sales and brand loyalty.

In $2024$ the company employs $200$ people. In an effort to retain staff the company provides a gen$-$erous package of benefts to its employees. Part of the beneft package includes participation in

a stock option plan and the availability of interest$-$free loans. In $2024,150$ employees own shares

in the company. The company has issued two classes of shares. Ayan, Spencer, Seda, and Pablo

each own $25\%$ of the common shares, and the employees own all of the Class A preferred shares,

which are non$-$voting but offer a participating cumulative dividend. No single employee owns more

than $1\mathrm{.}5\%$ of the preferred shares.

Three types of interest$-$free loans are offered for specifc purposes once an employee has passed

a p