Final T2 (Income inclusion and Insolvency deduction)

Working on:
2024 T2 (final return up to dissolution date - business closed operations - 2023)
&
2023 T1 (sole shareholder)

Business:

  • Went Insolvent 2023 (2023 T2 just filed - loss carryback completed to 2021)
  • Will be dissolved 2024 (after corp receives refund from loss carryback)
    Two things on BS in coming weeks after things wrap up:
  • $12k negative RE
  • $12k SH loan (credit balance)

Personal tax:

  • Personally sold rental property - 2023 (capital gain)

Rather than claim ABIL on T1 and potentially deal with CRA I’ve been told by a very knowledgeable member of this community that it may be wise to claim a Capital Loss on T1 for SH loan bad debt via ITA 50(1)(a) bad debt. This is a deeming rule.

Election potentially would not be necessary if corp was dissolved because SH loan would be disposed of.

  1. First question is about timing - would it be best to use deeming election now while corp is insolvent or wait for corp dissolution before filing 2023 T1?
    Goal: Bad debt loss to apply to 2023 Capital Gain

Please see screenshot below SCH 003:

For accounting (JE):
Debit Shareholder loan $12,000
Credit Other income - Debt forgiveness $12,000

For tax:

  • $12,000 - Other Revenue GIFI 8230
    (professional fees around $4,200)
    Net Income = $12,000 - $4,200 = $7,800

Please see screenshot of SCH 004 (non capital loss at the end of the previous year $5937 will be used against Net income)

I’ve read remaining income amount is multiplied by 50% and included income and if comp is insolvent there’s a corresponding insolvency deduction.

2. Can anyone explain application in T2 of:
(i) income being multiplied by 50%?
(ii) insolvency deduction?