The CRA has issued a pipeline ruling where the ACB of the shares being used to extract funds from a corporation is derived from a deemed disposition pursuant to the 21-year rule. Eric Hamelin, “Pipeline Transactions and the 21-Year Rule”, Tax for the Owner-Manager 19:2 (April 2019).
The foregoing article also provides a useful introduction to the risks of a pipeline and its mechanics. It also identifies some limitations of the comfort provided by the CRA in the ruling.
