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Question - Darlene Saunders has operated an unincorporated business for over 10 years. The business has been very successful and has now reached a point where it is producing more income than she requires for her personal needs. Given this, she would like to transfer the business to a new corporation, using the provisions of ITA 85(1). At the transfer date, the tangible assets of the business have tax values of $375,000. Their fair market value is $1,190,000. In addition, because of the success of the business, it is estimated that the business has goodwill of $320,000. At the transaction date, liabilities total $115,000. The elected value for the transfer will be equal to the tax values of $375,000. The corporation will assume the $115,000 in liabilities that are on the books of the business. In addition, Darlene will receive debt of $85,000 and common shares with a fair market value of $1,310,000. Determine the PUC of the common shares received by Darlene in the transfer.
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