This publication provides the full text of questions from CALU and written responses from the Canada Revenue Agency (CRA) addressed during the Canadian Life and Health Insurance Association (CLHIA) biennial CRA Roundtable on September 18, 2025. The CRA was represented by Bob Naufal, Manager, Financial Institutions Section, Income Tax Rulings Directorate, and the Roundtable moderated by Patrick Uzan, BA, CPA, CA, TEP, CLU, Vice-President, Professional Services at PPI.
Additional CALU commentary follows each answer from the CRA.
Topics covered in this report include:
- Deemed value rules for life insurance and qualified small business corporation (QSBC) shares
- Capital Dividend Account (CDA) anti-avoidance rule in subsection 83(2.1) of the Income Tax Act
- Donation of shares and dividend refund
- Term conversion – Capital Dividend Account (CDA)
- Section 148(7) of the Income Tax Act and addition to transferee’s Adjusted Cost Base (ACB)
We extend thanks to our Tax Advisor, Kevin Wark, for preparing this CALU Special Report, and to the following CALU Members and Associate Members who served on a Committee that prepared questions for consideration by the CRA: Iqbal Amiri, Ladelle Baar, Hemal Balsara, Kit Bennett, Sanjana Bhatia, Florence Marino, Steve Meldrum, and Patrick Uzan.
(Members only)
