Finance is not proceeding with the July, 2017, proposals to amend 84.1 and introduce new 246.1. Also, Finance has said that it will focus on developing the passive income proposals. Finance has also said, however, that it believes post-mortem gains in a private corporation should be taxed at the dividend rate and not the capital gain rate. Should advisers implement inter vivos pipelines to anticipate rules aimed at the post-mortem variety?

Issues for the pipeline remain with the July proposals. For example, see 120.4(4) and (5). [This article was written before the release of the December version of the TOSI rules.]

Manu Kakkar “The Pipeline Comes Back to Life (But for How Long?)” 18:1 Tax for the Owner-Manager (January 2018)