CRA sets out conditions for paying a refund, previously owing to a dissolved sub, to the parent

CRA’s starting point is to consider that when a sub has been wound up into its parent and dissolved, its right to receive a refund of an overpayment also ceases. However, if "all returns have been filed up to the date of dissolution, the articles of dissolution indicate that the corporation will distribute its assets to the shareholder…after satisfying its creditors [the articles of dissolution will not state this but presumably a general conveyance will do the trick],… the shareholder is the rightful owner of the funds and the sole shareholder completes and returns a signed ‘Release and Indemnification' form to the CRA," then CRA "may" issue the refund to the parent.

Neal Armstrong. Summary of 18 November 2014 TEI Roundtable, Q. E.4 under s. 164(1).