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CALU Report – Update on post-mortem pipeline planning

The Tax Court of Canada (TCC) decision in Robillard v. The Queen is a recent example of the tax uncertainty involving a post-mortem pipeline plan that was challenged by the Canada Revenue Agency (CRA). As discussed in this report by Sanjana Bhatia from Sun Life Financial, there continues to be two main uncertainties for those who wish to implement a pipeline strategy. These are: the appropriate timing of the winding-up of the business owner’s corporation, and the repayment terms of the promissory note (or timing of the redemption of preference shares, depending on how the pipeline strategy was implemented) ...

September 7, 2022|Categories: Publications|

Overview of the FHSA

Budget 2022 announced a new savings account for first time home buyers – the Tax-Free Home Savings Account (FHSA). This is one of several initiatives designed to make housing more affordable for younger Canadians. In effect, the FHSA combines the best features of an RRSP (tax-deductible contributions and tax deferred income) and a TFSA (tax-free withdrawals for a qualifying first home purchase). It is an alternative to the Home Buyers' Plan which allows for the tax-free withdrawal of up to $35,000 from an RRSP to purchase a qualifying first home. However, unlike the HBP, there is no requirement to ...

August 25, 2022|Categories: Publications|

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 ...

August 10, 2022|Categories: Publications|

INFOexchange 2022 vol. 2 is now available

INFOexchange 2022 volume 2 is now available! This issue includes Kelly Adams' first message as CALU Chair and Kate Pal's Government Relations update discussing Budget 2022, the CALU 2022 Conference & AGM and CALU's advocacy plans for the summer. Finally, we have two expert articles authored by CALU Tax Advisor, Kevin Wark on Offshore LIA structure in CRA's cross hairs and New reporting rules.(Members only) Download now

July 7, 2022|Categories: Publications|

CALU Special Report – 2022 CRA‐Finance roundtable Q&A

Our recent 2022 Conference & AGM featured a CRA-Finance Canada roundtable where senior representatives from those organizations responded to CALU's questions on tax policy and legislation matters, technical interpretations and audit-related issues.This CALU Special Report provides the full text of both the CRA questions and written responses, as well as the Finance Canada written questions and a summary of their verbal responses. CALU commentary has also been included where appropriate.Please contact Kevin Wark ( should you have any questions relating to the CRA and Finance responses and related commentary.(Members only) Download the report

June 28, 2022|Categories: Publications|

CALU Report – Corporate-owned health insurance

In this brand new CALU Report now available for members, author Stuart Dollar of Sun Life Financial discusses the Income Tax Act and its flexibility for life insurance policies allowing them to better meet the business and personal needs of incorporated businesses and their shareholders than health insurance. However, health insurance can meet many business insurance needs that life insurance cannot. (Members only) Download the report

June 2, 2022|Categories: Publications|

CALU Special Report: Federal Budget 2022

Finance Minister Chrystia Freeland tabled the Liberal government’s 2022 budget yesterday. Budget 2022, A Plan to Grow Our Economy and Make Life More Affordable, was a departure from the era of massive stimulus spending for COVID-19 measures, while attempting to maintain key Liberal tax and social policy themes and introducing several new initiatives to reflect current challenges such as housing and defence. This CALU Special Report highlights proposed government initiatives and tax proposals of greatest interest to our members and their clients. We extend our thanks to Kevin Wark and Angela Ross, CALU's tax advisors, for their work in ...

April 8, 2022|Categories: Publications|

INFOexchange 2022 vol. 1 is now available

INFOexchange volume 1 is now available for members! Chair Barry Pascal reflects on his time as CALU chair as it approaches its end. Followed is our GR Column covering the legislative agenda and governmental updates and two informative articles written by CALU Tax Advisor, Kevin Wark: Does Subsection 70(5.3) apply to corporations? The Underused Housing Tax – A whole new act! (Members only) DOWNLOAD NOW

March 31, 2022|Categories: Publications|

CALU Report – Recent estate planning developments in Canada

In this expert CALU Report now available for members, authors Rachel Blumenfeld and Marni Pernica of Aird & Berlis LLP provide an overview of key legislative changes relating to estates and substitute decision-making laws in Canada and discuss recent case law on beneficiary designations and the presumption of resulting trust,

March 3, 2022|Categories: Publications|




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