Mr. Cecil Tyrone owns 100% of the shares of CT Industries, a CCPC with a December...

  

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Mr. Cecil Tyrone owns 100% of the shares of CT Industries, a CCPC with a December 31 taxation year end. The company was incorporated by Mr. Tyrone with an investment of $84,000 for common shares. Mr. Tyrone is 73 years old and has no heirs with an interest in taking over the corporate business. He would like to sell the corporate business and devote his attention to the study of astronomy. He has received two offers for the corporation. The first, made by Ms. Heather Greenwand, is an offer to buy all of the shares for $1,450,000. The second offer has been made by Mr. Barkley Charms, and is an offer to acquire the assets of the business. The specific assets that he would buy, and the prices that he is offering, are as follows: Accounts Receivable Inventories Land Building Goodwill Total Both offers would require the purchase to take place on January 2, 2021. On January 1, 2021, the Balance Sheet of CT Industries is as follows: Term Deposits Accounts Receivable (Face Amount = $62,000) Marketable Securities at Cost (Equal to FMV) Inventories at Cost Land at Cost Building at Carrying Value* Total Assets Liabilities PUC Retained Earnings Total Equities $ 58,000 185,000 411,000 406,000 451,000 $1,511,000 $158,000 51,000 173,000 150,000 102,000 156,000 $790,000 $221,000 84,000 485,000 $790,000 *The capital cost of the building is $363,000 and it is the only property in its CCA class. The UCC of the class is $112,000. On January 1, 2021, there is no balance in the company's CDA (CDA), Eligible RDTOH, Non-Eligible RDTOH, or GRIP account. The term deposits has been owned by the company for over five years. They represent an investment of excess funds. Mr. Tyrone had no personal need for these funds and he wished to defer personal taxation on the earnings they were generating. All of the company's non-current property were acquired in the last 10 years. The provincial income tax rate on corporate income that is eligible for the small business deduction is 3% and 12% on other corporate income. Mr. Tyrone has other income in excess of $250,000 and, as a consequence, his federal income tax rate on all additional income is 33% and his provincial income tax rate is 16%. He resides in a province where the provincial dividend tax credit on eligible dividends is 5/11 of the gross up, and on non-eligible dividends is 4/13 of the gross up. Mr. Tyrone has not used any of his capital gains deduction. If Mr. Tyrone accepts Mr. Charms' offer to purchase the assets of the business, Mr. Tyrone will sell the term deposits and marketable securities for their accounting carrying values which are equal to their FMV. With respect to the sale of the accounts receivable, Mr. Charms and Mr. Tyrone will jointly elect to sell/transfer them using the election under ITA 22. There would be a winding-up of the corporation subsequent to the sale of all of its assets. Required: Determine which of the two offers will provide Mr. Tyrone with the largest amount of personal after tax funds. Ignore the possibility that Mr. Tyrone might be subject to the alternative minimum tax (AMT). Assume that appropriate elections or designations will be made to minimize Mr. Tyrone's personal income tax liability. Mr. Cecil Tyrone owns 100% of the shares of CT Industries, a CCPC with a December 31 taxation year end. The company was incorporated by Mr. Tyrone with an investment of $84,000 for common shares. Mr. Tyrone is 73 years old and has no heirs with an interest in taking over the corporate business. He would like to sell the corporate business and devote his attention to the study of astronomy. He has received two offers for the corporation. The first, made by Ms. Heather Greenwand, is an offer to buy all of the shares for $1,450,000. The second offer has been made by Mr. Barkley Charms, and is an offer to acquire the assets of the business. The specific assets that he would buy, and the prices that he is offering, are as follows: Accounts Receivable Inventories Land Building Goodwill Total Both offers would require the purchase to take place on January 2, 2021. On January 1, 2021, the Balance Sheet of CT Industries is as follows: Term Deposits Accounts Receivable (Face Amount = $62,000) Marketable Securities at Cost (Equal to FMV) Inventories at Cost Land at Cost Building at Carrying Value* Total Assets Liabilities PUC Retained Earnings Total Equities $ 58,000 185,000 411,000 406,000 451,000 $1,511,000 $158,000 51,000 173,000 150,000 102,000 156,000 $790,000 $221,000 84,000 485,000 $790,000 *The capital cost of the building is $363,000 and it is the only property in its CCA class. The UCC of the class is $112,000. On January 1, 2021, there is no balance in the company's CDA (CDA), Eligible RDTOH, Non-Eligible RDTOH, or GRIP account. The term deposits has been owned by the company for over five years. They represent an investment of excess funds. Mr. Tyrone had no personal need for these funds and he wished to defer personal taxation on the earnings they were generating. All of the company's non-current property were acquired in the last 10 years. The provincial income tax rate on corporate income that is eligible for the small business deduction is 3% and 12% on other corporate income. Mr. Tyrone has other income in excess of $250,000 and, as a consequence, his federal income tax rate on all additional income is 33% and his provincial income tax rate is 16%. He resides in a province where the provincial dividend tax credit on eligible dividends is 5/11 of the gross up, and on non-eligible dividends is 4/13 of the gross up. Mr. Tyrone has not used any of his capital gains deduction. If Mr. Tyrone accepts Mr. Charms' offer to purchase the assets of the business, Mr. Tyrone will sell the term deposits and marketable securities for their accounting carrying values which are equal to their FMV. With respect to the sale of the accounts receivable, Mr. Charms and Mr. Tyrone will jointly elect to sell/transfer them using the election under ITA 22. There would be a winding-up of the corporation subsequent to the sale of all of its assets. Required: Determine which of the two offers will provide Mr. Tyrone with the largest amount of personal after tax funds. Ignore the possibility that Mr. Tyrone might be subject to the alternative minimum tax (AMT). Assume that appropriate elections or designations will be made to minimize Mr. Tyrone's personal income tax liability.

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