CRA rules on a pipeline transaction for the estate of a minority shareholder of a portfolio investment company

CRA has also issued a ruling on some more complex pipeline transactions involving a minority shareholding of an estate in a portfolio investment company ("Holdco"). The other shareholders are the three surviving siblings, and trusts for the extended family. In order that the Newco used to extract the estate’s share of corporate surplus will be connected to Holdco for Part IV tax purposes, the trust which controls Holdco will acquire the voting common shares of Newco.

Neal Armstrong. Summary of 2015 Ruling 2014-0541261R3 F under s. 84(2).