In Robillard (Succession) c R, 2022 CCI 13, an estate completed a pipeline for a corporation within seven months of the death of its shareholder. The CRA applied 84(2) to the pipeline. The taxpayer appealed. The Court, after criticizing Canada v. MacDonald, 2013 FCA 110, nevertheless held that it was bound by the decision and dismissed the taxpayer’s appeal.
Robert Santia “TCC Bursts Post Mortem Pipeline” 12:2 Canadian Tax Focus (May 2022)
