CRA confirms that it can issue a clearance certificate before a corporate dissolution

Where there are multiple legal representatives, e.g., executors or directors, CRA will issue a single s. 159(2) certificate to the person whose name first appears on the request for the certificate, but will include the names of all the other legal representatives on that certificate - and, if more than one address is provided, send a copy of the certificate to the other addresses. CRA also stated:

There is no requirement for a corporation to be dissolved prior to the request of a clearance certificate. The CRA can issue a partial clearance certificate if the articles of dissolution are pending closure or we believe the intent is to dissolve the corporation.

No response was given to the suggestion that corporate directors are not legal representatives during the corporation’s existence.

Neal Armstrong. Summary of May 2017 CPA Alberta Roundtable, ITA Q.7 under s. 159(2).