CRA rules on post-mortem pipeline

CRA ruled on a conventional post-mortem pipeline: following preliminary transactions to generate a capital loss for carryback to the terminal year pursuant to s. 164(6), the estate sold its shares of “Investco” (described as carrying on a “business” of investing in GICs and other portfolio investments) to a Newco for consideration consisting mostly of a note, with Newco amalgamating with Investco after at least one year, and the note repaid on a quarterly basis thereafter.

Neal Armstrong. Summary of 2022-0955451R3 F under s. 84(2).