Clearwater Seafoods - Federal Court of Appeal finds that the successor to a terminated trust could continue its tax appeal

When a taxpayer ceases to exist, its tax appeal is extinguished, right?

Sharlow JA effectively found that when the subsidiary trust of an income fund was wound-up as part of the income-fund conversion procedures contemplated in s. 88.1, the public company which received all its property could continue a tax appeal of the former trust, provided that some routine facts were confirmed at the Tax Court level.

Neal  Armstrong.  Summary of Clearwater Seafoods Holdings Trust v. The Queen, 2013 FCA 180, under s. 169.