Request for a technical interpretation relating to life insurance and retirement compensation arrangements

As part of the package of questions provided to the Canada Revenue Agency (CRA) in preparation for the 2014 CALU CRA and Finance Roundtable, CALU posed a question concerning life insurance held by a retirement compensation arrangement. CALU’s question set out a fact pattern involving a “top-up pension” retirement compensation arrangement (RCA) that held life insurance as an investment to fund the promised pension payments under the RCA. The CRA declined to respond to the question and instead suggested that CALU put in a request for a technical interpretation. In August 2014, CALU’s Tax Consultant Jillian Welch made a submission to the CRA, on CALU’s behalf, requesting a technical interpretation on how the advantage rules might be applied to life insurance within an RCA.