CRA provides favourable rulings for post-mortem pipeline planning
In 2014-0563081R3 and 2014-0526431R3 (in French), the Canada Revenue Agency issued advance income tax rulings confirming that subsections 84(2) and 245(2) of the Income Tax Act (Canada) would not apply as a result of proposed transactions implementing post-mortem pipeline structures where (1) the intervening period between the time the shares of a particular corporation are transferred by the estate to a newly formed corporation (“Newco”) and the time that the particular corporation is amalgamated with or wound up into Newco would be at least one year and (2) during that year, the particular corporation would continue to carry on its business in the same manner as previously.