New paragraph 212.1(6)(b) deems Newco to have paid dividends to non-resident beneficiaries of an estate that is implementing a pipeline so that Newco must pay withholding tax. The change is effective from budget day, 2018, even though nothing in the budget documents or initial draft legislation indicated that the rule changes to section 212.1 were aimed at pipelines. Marshall Haughey, “Pipelines and Non-Resident Beneficiaries” Canadian Tax Highlights 27:3 (March 2019).
Update March 2, 2020: See Henry Shew, “Finance Revives Post Mortem Pipeline for Non-Resident Beneficiaries” (February 2020) 10:1 Canadian Tax Focus
