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

Previously asked questions, Can I get the answers to questions asked by oth...

Can I get the answers to questions asked by others? they are on this page http://www.expertsmind.com/questions/corporate-tax-301114747.aspx#

The maximum capital cost allowance claim, During the current year, Denos Co...

During the current year, Denos Corporation incurred costs of $45,000 for leasehold improvements to its newly rented building. The lease was signed in the current year for an initia

Salary, what is the rule of travelling allowance of 2013-14

what is the rule of travelling allowance of 2013-14

Compute the cost of debt, A company issues 15-year, $1,000 par-value bonds,...

A company issues 15-year, $1,000 par-value bonds, with a coupon rate of 5%. The bonds are sold for $619.70. The tax rate is 30%. Compute the cost of debt before taxes and after tax

Indirect taxes, disadvantages of indirect taxes

disadvantages of indirect taxes

Sales tax, Arnold and Beth file a joint return. Use the following data to c...

Arnold and Beth file a joint return. Use the following data to calculate their deduction for AGI. Mortgage interest on personal residence $ 4,000 Property taxes on personal resi

Compute the cost of external equity, Suppose a company issues common stock ...

Suppose a company issues common stock to the public for $25 a share. The expected dividend is $2.50 per share and the growth in dividends is 8%. If the flotation cost is 10% of the

Independence standard board, Independence Standard Board (ISB) - This is pr...

Independence Standard Board (ISB) - This is private sector standard-setting body governing the independence of AUDITORs from their public company clients. It came about from discus

Role of media play in marketing mix, Role of media play in marketing mix: ...

Role of media play in marketing mix: A. The article discusses the market prospects for automotive technology for producing driverless cars with the potential to reduce road ac

Determine the maximum cca , Lambda Ventures, an unincorporated business, ha...

Lambda Ventures, an unincorporated business, has a class 10 UCC balance on January 1, 2010 of $453,000.During 2010, it acquires additional Class 10 assets at a cost of $63,200.Also

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