Aco acquired all of the shares of Bco for a price of $1000, resulting in an acquisition of control. Bco’s only assets were Class 43 and 8 assets with an aggregate UCC of $1100 that were valued by a professional valuator immediately before the acquisition of control as having an aggregate FMV of $1500. Should the depreciable property be valued as per the appraisal or based on the $1000 share purchase price?
CRA indicated that the depreciable property should be valued in aggregate based on the $1000 share purchase price, but that such aggregate could be allocated between the two classes based on the appraisal.