Adam would transfer the assets to the partnership using the rollover provision of subsection 97(2) — and Amit formed this year operate retail store specializing gag gifts who

General StudiesGeneralWorked Solution

Adam and Amit formed a partnership this year to operate a retail store specializing in gag gifts. Adam, who has been in the business for about 13 years as a sole proprietor, owned the following assets:

Adam transferred these assets to the partnership on February 1, 2008, in exchange for a 60% partnership interest. Amit contributed $59,000 in cash and marketable securities with a fair market value of $30,000 in return for a 40% interest. The marketable securities were purchased about 12 years ago at a cost of $25,000.

REQUIRED

(A) How can Adam’s assets be transferred to the partnership without immediate tax consequences? What is the cost to the partnership of Adam’s assets?

(B) What is the maximum non-partnership consideration that Adam can receive without adverse tax consequences?

(C) What is the adjusted cost base of his partnership interest to Adam, assuming that the only consideration received for the transferred assets is a partnership interest?

(D) What is the adjusted cost base of his partnership interest to Amit, assuming that (i) the only consideration received for the transferred assets is a partnership interest and (ii) Amit and the partnership elected jointly to have the rollover provisions [ssec. 97(2)] apply to the transfer?

SOLUTION

(A)

Adam would transfer the assets to the partnership using the rollover provision of subsection 97(2).

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