Has there been any change to the position in IT-302R3 that a change of executor, administrator or trustee of an estate does not result in an acquisition of control of a corporation controlled by the estate, if the replacement results from a death or inability to fulfill the function of an executor, administrator or trustee.
CRA indicated that where the executor, administrator, or trustee of an estate is replaced as a result of that person’s death or inability to fulfill their function, control of the corporation would not be acquired solely as a result of that replacement. This position is not conditional on the replacement trustee being related or otherwise connected to the executor, administrator or trustee being replaced.