The Tax Court of Canada (TCC) decision in Robillard v. The Queen is a recent example of the tax uncertainty involving a post-mortem pipeline plan that was challenged by the Canada Revenue Agency (CRA). As discussed in this report by Sanjana Bhatia from Sun Life Financial, there continues to be two main uncertainties for those who wish to implement a pipeline strategy. These are:

  • the appropriate timing of the winding-up of the business owner’s corporation, and
  • the repayment terms of the promissory note (or timing of the redemption of preference shares, depending on how the pipeline strategy was implemented)

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