Cross-Border Life Insurance Planning: A Canadian-U.S. Case Study
This CALU Report analyzes the intersection of Canadian and United States tax law, specifically focusing on the use of corporate-owned life insurance within a closely held Canadian private corporation. Ultimately, there is often no perfect solution when dealing with these cross-border insurance planning scenarios and clients will sometimes have to “pick their poison.” We thank Robin Goodman and Marla Waiss for authoring this publication. (Members only) Download Now
Akhavan v. The King: Taxation of return of premium benefits
This short publication discusses the tax treatment of a return of premium (ROP) benefit from the maturity of a term life insurance policy, based on a recent Tax Court of Canada case, Akhavan v. The King. It explains why the ROP in the Akhavan case was taxable, discusses the tax treatment for other types of ROP benefits, and concludes with recommendations for CALU members whose clients are thinking of buying a life insurance policy with an ROP benefit. Download now
CALU Practice Note: Bare trusts and life insurance
Bare trusts have long been used for personal and business planning purposes, and in recent years, have also been used to own life insurance policies. Read the public summary of our Practice Note for CALU members here. The Practice Note covers various related topics including recent changes to the tax treatment of bare trusts, and issues/concerns with the ownership of life insurance by bare trusts. It also provides best practices for advisors regarding bare trusts owning life insurance. Public summary Members only Practice note
INFOexchange 2026 vol. 2 is now available!
In our second INFOexchange of 2026, you’ll read: ✔️ First message from CALU’s Board Chair for 2026-2027, Laura Klaehn ✔️ Expert article on “Tips for estate planning with Letters of Wishes” by Suzana Popovic-Montag ✔️ Expert article on “Using a trust for corporate insurance purposes” by Kevin Wark We thank Associate Members Florence Marino and Patrick Uzan for their review of Kevin Wark’s article. (Members only) Download the report
CALU Special Report: 2026 CRA-Finance Roundtable
Following from the Canada Revenue Agency (CRA) and Finance Canada Roundtable held at our 2026 Conference & AGM, this CALU Special Report provides the full text of the written questions and responses from the CRA, as well as the written questions to Finance Canada and a summary of their verbal responses. CALU’s commentary on the CRA responses is also included where appropriate. The Roundtable session took place on May 5, 2026 to allow participants to hear from senior representatives from both organizations on CALU’s questions of tax interpretation, administration and policy. Download the report
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
INFOexchange 2026 vol. 1 is now available!
In our first INFOexchange of 2026, you’ll read: ✔️ Final message from CALU’s Chair of the Board of Directors for 2025-2026, Sterling Rempel ✔️ Advocacy update from the Chair of the Tax Policy and Advocacy Committee, Melanie Weinberg ✔️ Expert article on “The Capital Dividend Account – Avoiding Misconceptions” by Patrick Uzan ✔️ Expert article on “Estate Planning Gone Awry” by Kevin Wark We thank Associate Members Jeannie Lim and Florence Marino for their review of the expert articles. (Members only) Download the report
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
