CALU Report – Moving to Canada with a Foreign Insurance Policy: A Case Study (update)
In this February 2019 issue of the CALU Report, it was stated that subsection 70(5.3) provides that for purposes of section 128.1, the FMV of a foreign life insurance owned by a non-resident corporation on the life of shareholder, which corporation subsequently becomes resident in Canada as a consequence of the shareholder becoming a resident of Canada, shall be determined as though the FMV of the life insurance policy on the shareholder’s life was the CSV of the policy immediately prior to immigrating to Canada. However, in a recent CRA technical interpretation provided to CALU, the CRA expressed the ...
