CRA considers that payment to an unsecured creditor by an executor is a "distribution"

CRA has stated that an executor or other legal representative must obtain a certificate under s. 159(2) before paying off a credit card company (or otherwise distributing property to an unsecured creditor) if the taxpayer in question owes tax, or else the representative will be personally liable under s. 159(3) for the amount distributed.  However, CRA also appears to imply that it will not require a certificate before such a "distribution" is made to a secured creditor.

Scott Armstrong.  Summary of 27 March 2013 Memorandum 2012-0457251I7 under s. 159(2).