Sally would like to transfer her assets ABC Limited, which she owns in exchange for note payable
Question:
Sally would like to transfer her assets ABC Limited, which she owns in exchange for note payable and preferred shares of ABC Limited. She wishes to receive the maximum amount in note payable that she can receive in the future and still defer the recognition of income for tax purposes on the transfer of the assets. Sally and Limited Inc. will jointly make a Section 85 election for each of the assets. The following are the details of the assets:
Required:
1) For each of the four assets individually, state the amount that should be elected as proceeds under Section 85 of the Income Tax Act, and state the amount of the gain/loss/profit that would be deferred if Section 85 was not elected.
2) For each of the four assets individually, state the amount of cash and the value of the common shares that Sally should accept as payment for the assets
Answer the question in great detail.
Introduction To Federal Income Taxation In Canada
ISBN: 9781554965021
33rd Edition
Authors: Robert E. Beam, Stanley N. Laiken, James J. Barnett