CRA rules on pipeline accomplished through the Newco purchaser issuing 8 instalment notes to the estate as a PUC reduction
CRA provided s. 84(2) and 84.1 rulings on a pipeline transaction in which the estate sells the investments company, which it acquired on the death of the deceased, to a Newco formed by it in consideration for high-PUC shares. Then, after the specified delay (presumably, one year), Newcos effect a distribution to the estate of that PUC through the issuance of eight (presumably equal-amount) promissory notes payable at successive quarterly intervals at the beginning of each of the 8 quarters commencing at that one-year mark. Later, Newco and the investments company amalgamate.
Neal Armstrong. Summary of 2022 Ruling 2022-0925601R3 F under s. 84(2).