Mrs. Sam Taffer was a brilliant engineer at IBM and made a lot of money from stock

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Question:

Mrs. Sam Taffer was a brilliant engineer at IBM and made a lot of money from stock options. Since then, she has worked as a musician and raised her two sons. She wishes to have most of her property ultimately pass to them. In a move designed to help achieve this goal, she gifted a substantial amount of her property to a trust in their favour 15 years ago. The taxation year of the trust ends on December 31, and Mrs. Taffer has no beneficial interest in either the income or capital of the trust. The terms of the trust provide for the older son, Jonathan, age 38, to receive 35% of each type of income of the trust, while the younger son, Robert, age 35, is to receive a 25% share. Trust income includes any capital gains earned in the trust. Both Jonathan and Robert Taffer are single and have no income other than income from the trust. The undistributed income is to accumulate within the trust, to be paid out to the two sons at the time of Mrs. Sam Taffer's death. The reported trust income for the 2022 taxation year is as follows:

Interest Income on government bonds	$25,000
Eligible dividends received from Canadian corporations	245,488
Revenue from rental property	386,000
Cash expenses on rental property	229,000

On September 1, 2022, the rental property was sold. The property consisted of an apartment building and the land on which it was located, all of which was gifted to the trust when it was established. The relevant information related to the disposition is as follows:

	Building	Land
POD	$1,857,000	$1,100,000
UCC	1,371,000	n/a
ACB	1,608,000	785,000

This is the first disposition of capital property by the trust since it was established.

Required:

a. Calculate the 2022 net income and taxable income of the trust, Jonathan Taffer, and Robert Taffer.(13 marks)

b. Calculate the 2022 federal income tax payable for the trust.(5 marks)

c. Will the 21-year deemed disposition rule affect the trust or beneficiaries in 2022? What actions should be taken to mitigate the effect of the rule and when?(2 marks)