What are the tax consequences associated with a corporation issuing shares to a creditor in order to retire a debt that has a carrying value lower than the PUC of the shares issued?
A) There will be a reduction in PUC and ACB for all the shares that were outstanding prior to the debt retirement transaction.
B) There will be a deemed dividend which will be allocated to all shareholders including the new shareholder who acquired shares by giving up debt securities. The adjusted cost base of the shares will increase by the amount of the deemed dividend.
C) There will be a deemed dividend allocated to the new shareholder who acquired shares by giving up debt securities. The adjusted cost base of the shares will increase by the amount of the deemed dividend.
D) There will be a deemed dividend allocated to all shareholders including the new shareholder who acquired shares by giving up debt securities. The adjusted cost base of the shares will not be affected.
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