In the course of confirming that its position on pipeline transactions has not changed as a result of s. 246.1 being proposed, nor of it being dropped, CRA referenced with approval the positions taken at STEP 2011 (2011-0401861C6).
If the funds or property of the original corporation were to be distributed to the estate in a short timeframe following the death of the testator, that would raise concerns.
CRA will continue to issue favourable rulings where the facts of the proposed transaction do not involve a cash corporation, and contemplate the continuation of the particular business for a period of at least one year, to be followed by a progressive distribution of the corporate assets over a period of time.