User Account

All Pages

Estate Freeze, Taxation

Assignment Help:
Exhibit
Additional information
• Andy currently owns all of the shares of Grand Inc., a CCPC with 1,000 common shares issued and outstanding. Grand Inc. operates an active business in Canada and is a small business corporation with a December 31st year-end. Andy’s shares of Grand Inc. are qualified small business corporation (QSBC) shares
• Grand Inc. was incorporated in 1985 by Andy’s aunt, Mary. In 1985 Mary subscribed for 1,000 common shares of Grand Inc. and paid $3,000, in aggregate, into the company to buy the shares. In 1999 Mary retired and sold all her 1,000 common shares to Andy for $220,000, in aggregate, which was their fair market value (FMV) at the time
• Some friends of Andy’s have done estate freezes themselves and suggested that Andy do something similar. Andy thinks the value of Grand Inc. will increase over the next several years and after discussions with his friends Andy wants to do the following estate freeze in the near future:
1) Grand Inc. will undergo a reorganization of capital, where Andy’s 1,000 common shares will be given up in return for 500 new non-voting preferred shares. Andy does not want to use subsection 85(1) of the Act when doing this reorganization of capital;
2) Andy’s adult children, who are very mature and business savvy, will subscribe for 100 new common shares of Grand Inc. Hence, the children will have voting control of Grand Inc. which Andy is fine with;
3) Andy will sell his 500 non-voting preferred shares of Grand Inc. to Tsai Family Holding Company in return for $800,000 in cash. Tsai Family Holding Company is 50% owned by Andy and 50% owned by Andy’s children and it has lots of cash and liquid assets. Since Andy has never used his capital gains exemption before
Andy’s friends believe he can get the $800,000 tax-free. Grand Inc.’s most recent (December 31, 2013) balance sheet shows the following information (and these figures have remained stable for the past 24 months):
ACB (original
cost) UCC FMV
Active business assets (excluding goodwill) $700,000 $500,000 $600,000
Cumulative eligible capital (goodwill) $20,000 $10,000 $300,000
Long-term portfolio investments $40,000 n/a $60,000
$960,000


draft a report describing and calculating the federal income tax consequences to Andy from the proposed estate freeze. You should give Income Tax Act (ITA) section, subsection and paragraph (where applicable) references in order to support your answer.

Related Discussions:- Estate Freeze

Sale of principal residence, Sale of a Principal Residence. Marc, age 45, s...

Sale of a Principal Residence. Marc, age 45, sells his personal residence on May 15, 2014, for $180,000. He pays $8,000 in selling expenses and $900 in repair expenses to help sell

Share returns, The tab-delimited text file C223C323_A1_S1_2013_Q1_Q2.txt co...

The tab-delimited text file C223C323_A1_S1_2013_Q1_Q2.txt contains data on the share price of FirstGroup plc (FirstGroup), the public transport company, the share price of Cairn En

Compute the effective income tax rate for 2013 and 2014., The following ite...

The following items caused the only differences between pretax financial income and taxable income. • In 2013, the company collected $90,000 of rent; of this amount, $30,000 was ea

Advanced Tax, The Madison Restaurant was formed a S corporation at the end ...

The Madison Restaurant was formed a S corporation at the end of last year. Bob Buron, owns 60% of the stock, manages the restaurant. Ray Huges owns the remaining 40% of the stock

What reasons would a government introduce a tax, Question 1: "The legit...

Question 1: "The legitimate object of government is to do for a community of people whatever they need to have done, but cannot do at all, or cannot so well do, for themselves

Tax care, #queCongress recently enacted an non refundable credit based on t...

#queCongress recently enacted an non refundable credit based on the cost of the qualifying alcohol and drug abuse counseling programs provided by and corporate employer to its empl

Return of invesment.., return of invesment..

return of invesment..

Tax Basis Balance Sheet, Prepare a Tax Basis Balance Sheet for the partners...

Prepare a Tax Basis Balance Sheet for the partnership on its formation at the beginning of 2012

Tax return, I have an assignment that requires me to prepare a tax return ....

I have an assignment that requires me to prepare a tax return .

How much net income, Guay Corp a start up company provided services that we...

Guay Corp a start up company provided services that were acceptable to its customers and billed those customers for $350,000 in 2012. However, Guay collected only $280,000 cash in

Write Your Message!

Captcha
Order Assignment

Featured Services

Order Now

Popular Subjects

Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

Submit Assignment

Academics

Major Subjects

Majors

Get In Touch

whatsapp: +91-977-207-8620

Phone: +91-977-207-8620

Email: [email protected]

TERMS & POLICIES

HELP & SUPPORT

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd