CRA follows its practice of requiring one year to pass before a pipeline note commences to be paid off

CRA ruled on conventional pipeline transactions for a portfolio holding company (Holdco). Unlike most recent rulings it did not redact the period of time between the sale of Holdco to Newco for a note, and the amalgamation of Newco with Holdco (it was stated as “one year” rather than “12 months,” so that there was no naughty number to redact).

Neal Armstrong. Summary of 2020 Ruling 2019-0832601R3 F under s. 84(2).