The estate trustees brought an application seeking the court's opinion on whether life insurance proceeds payable to private corporations owned by the deceased should be included in the value of the shares for estate administration tax purposes.
The Minister brought a motion to dismiss the application, arguing that s. 29.1 of the Retail Sales Tax Act, incorporated by the Estate Administration Tax Act, prohibits such applications.
The court agreed, finding that the legislative scheme requires taxpayers to follow the statutory assessment, objection, and appeal process rather than seeking advance tax rulings from the court.
The Minister's motion was granted and the application was dismissed.
