On November 1, 2010, Chris purchased all the issued shares of..

On November 1, 2010, Chris purchased all the issued shares of Transtek Inc. from an acquaintance, Tom. Transtek carries on a transmission repair business and has done so since its incorporation on January 1, 2009. In addition to the transmission repair business, Transtek rents out a small building it owns. Neither the transmission repair business nor the rental endeavour has been successful.

When Chris purchased Transtek, his financial projections indicated that Transtek would have significant income within two years. Chris credited Transtek’s failure to Tom’s brash personality and laziness. Chris, on the other hand, has a strong work ethic and has many contacts in the automotive industry to refer work to him.

The values of the capital assets owned by Transtek at the time of purchase by Chris are as follows:

ITA: 111(4), 111(5), 111(5.1), 249(4)

Repair shop

Rental property

$32,000

22,500 2,500 4,500

— 9,000

$(75,000) $62,500

18,000 5,000 3,500 — 3,000

10,500 9,000

—

— 13,000

FMV . . . . . . . . . . . . . . . . . . . Cost/ACB …………… UCC ……………….

Land

$140,000 80,000

—

Building

$230,000 150,000 147,000

Land

$70,000 90,000

—

Building

$120,000 120,000 120,000

Chris selected June 30, 2011, as the first fiscal year-end for Transtek after his purchase. The following is a schedule of Transtek’s income (and losses) from its inception, January 1, 2009, through June 30, 2012.

Period

Jan. 1/2009-Dec. 31/2009 . . . . . Jan. 1/2010-Oct. 31/2010 . . . . . Nov. 1/2010-June 30/2011 . . . . July 1/2011-June 30/2012 . . . .

— REQUIRED

Transmission repair business

$(40,000) (60,000) (25,000)

54,000

Rental income (loss)

$(2,000) (5,000) 6,000 11,000

Capital Loss

$(10,000) —
—
—

(A) Discuss the tax implications of the acquisition of Transtek Inc. on November 1, 2010, ignoring all possible elections/options.

(B) Determine the tax consequences of the acquisition of Transtek Inc. under the assumption that:

(i) the maximum amount of all elections/options is utilized; and

(ii) the partial amount of all elections/options is utilized so that only enough income is generated to offset most or all of the losses which would otherwise expire on the acquisition of control.