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

Explain the motivations behind debt covenants, Explain the motivations behi...

Explain the motivations behind debt covenants: You are engineering a Leveraged-Buy-Out (LBO) of ACME Industries, an industrial bottle maker. After the LBO, the firm will be fina

Research assignment, The following assignment is due the last day of class ...

The following assignment is due the last day of class or at the final exam, in hard copy format only. You may complete the assignment in groups of 2-4, if desired. Indicate your

Calculate tax liability, I am zainab ali, i want help in Tax assignment.. ...

I am zainab ali, i want help in Tax assignment..   In 2012 Joe, age 15, earned $2900 from acting and had $12,200 of interest income and $14,000 of taxable qualified dividend

Research, Hi can you help me with my tax research and answer the following ...

Hi can you help me with my tax research and answer the following After reading the Treasury Department Circular 230 and AICPA statement of standard for tax services, answer the fo

Disregard the alternative minimum tax, Dan and Cheryl are married, file a j...

Dan and Cheryl are married, file a joint return, and have no children. Dan is a pharmaceutical salesman and Cheryl is a nurse at a local hospital. Dan%u2019s SSN is 400-20-1000 and

Payroll taxes assignment help, Assignments for Portfolio Development In...

Assignments for Portfolio Development In order to demonstrate college-level mastery of the course objectives, you will be required to write a narrative for your electronic port

Collective investment fund, A fund that is managed by a trust company or a ...

A fund that is managed by a trust company or a bank and deals with pooled collection of trust accounts. Collective investment funds combine together the assets of several individua

Tax umbrella, The use by a corporation of the losses it continued in earlie...

The use by a corporation of the losses it continued in earlier years to compensate taxes on the profits it attains in future years. Individuals can also utilize a tax umbrella so t

Computation, "Alfred E. Old and Beulah A. Crane, each age 42, married on Se...

"Alfred E. Old and Beulah A. Crane, each age 42, married on September 7, 2010. Alfred and Beulah will file a joint return for 2011. Alfred''''s Social Security number is 111-11-111

Write Your Message!

Captcha
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!

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