Look out for third-party civil penalties
This publication examines a revised circular from the Canada Revenue Agency (CRA) that expands the circumstances in which it may apply third-party penalties, and the potential implications for those promoting tax planning strategies that appear to offer certain advantages to taxpayers. Download now
Calmusky revisited
This Tax Byte discusses a recent Ontario Supreme Court decision – Kunka Estate v. Giasson – which confirmed that beneficiary designations on registered plans (such as TFSAs and RRIFs) are testamentary dispositions not subject to the presumption of a resulting trust. The Court rejected the controversial 2020 Calmusky v. Calmusky ruling which had sent tremors through the insurance and estate planning community in Ontario. The publication concludes with CALU’s advice to advisors in dealing with matters involving the presumption of resulting trust, and an alternate way to provide certainty for estate planners and their clients. Download now ...
Bill C-31 – Items of interest
This Tax Byte highlights items of interest to CALU members from Bill C-31, A second Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025, which was introduced in the House of Commons on May 6, 2026. The legislation implements measures announced in Budget 2025, as well as technical tax changes included in draft legislation released in August 2024 and August 2025. Download now
CALU 2026 pre-budget submission to Standing Committee on Finance
Our pre-budget submission to the Standing Committee on Finance in advance of Budget 2026 recommends that the federal government: Promptly begin its promised review of the corporate tax system, including a focus on small business taxation. Promptly update RRSP, RRIF and TFSA rules to better support the financial needs of those saving for retirement and retirees. Provide a temporary 35 percent refundable tax credit relating to the cost of dental care programs for employees of small businesses to be reviewed for effectiveness after three years. Develop pharmacare using the same general approach as the federal dental plan: supporting those ...
Measuring the Benefits of an Estate Freeze
This CALU Report by Jens Watson uses a case study involving a family-owned operating company to demonstrate the potential value of an estate freeze for both the founding business owners and their children. It concludes that it is often beneficial to implement an estate freeze before a business has experienced a substantial amount of growth in value (but not too early). We thank CALU Associate Members Daniel Balofsky, Florence Marino and Bryan McNulty for their review of the publication. Download Now
Advisor Checklist for leveraged life insurance arrangements
The Conference for Advanced Life Underwriting (CALU) has developed the following checklist for use by life insurance advisors when working with clients who are considering a leveraged life insurance program, either personally or through their corporation. download now
CALU Practice Note: Individually owned joint life insurance policies – Tax treatment and best practices
This Practice Note provides guidance to CALU members on the matter of individually owned joint life insurance policies on the death of an owner. We thank CALU’s Tax Advisor, Kevin Wark, and to members Ladelle Baar, Florence Marino and Steve Meldrum for their contributions to this publication. (Members only) download now
Singleton planning lives on despite GAAR changes
This publication discusses the impact of recent changes to the general anti-avoidance rule (GAAR) on Singleton planning arrangements. While concerns have been raised in the tax community that Singleton arrangements might be challenged by the Canada Revenue Agency (CRA) in the future, a recent technical interpretation appears to deal with this concern. Download now
CALU Practice Note: Taxable benefit rules and Holdco-Opco insurance arrangements
This Practice Note discusses taxable benefit issues arising from certain corporate-owned life insurance arrangements and outlines best practices for advisors to follow. We extend our thanks to CALU members Florence Marino, Bryan McNulty, David Stevens and Patrick Uzan for their contributions to this publication. (Members only) download now
Keystone decision and the Capital Dividend Account (CDA)
This Tax Byte discusses a recent court decision involving the Keystone corporation that paid an excess capital dividend to its individual shareholders. The decision reinforces the need for owners of private corporations (and their tax advisors) to properly determine their capital dividend account (CDA) balance before the payment of any capital dividends. Download now
