CRA’s pipeline policy has not changed

In the course of confirming that its position on pipeline transactions has not changed as a result of s. 246.1 being proposed, and then being dropped, CRA referenced with approval the positions taken at STEP 2011 (2011-0401861C6), and indicated that it will continue to issue favourable rulings where the facts do not involve a cash corporation, there is a continuation of the business for at least one year, and this is followed by a progressive distribution of the corporate assets.

Neal Armstrong. Summary of 29 May 2018 STEP Roundtable, Q.10 under s. 84(2).