CALU Practice Note – Best practices for insured leveraging programs – Part I
This Practice Note (Part I) will primarily focus on issues relating to marketing leveraged programs, client communications and disclosure, due diligence on lending arrangements and longer-term management issues. A following Practice Note (Part II) will build on previously issued Practice Notes and focus on the key tax issues pertaining to leveraged insurance strategies. The overall objective of this Practice Note (Parts I and II) is to provide guidance to CALU members on how to identify appropriate clients for insured leveraging programs and ensure they have the necessary information/advice so they can make an informed decision before implementation. Each client’s ...
New federal tax proposals and legislation – The top five
CALU has prepared a document listing the top five items you should know about from the federal government's Fall Economic Statement 2022 and new budget implemenation legislation (Bill C-32) tabled last week. Download now
INFOexchange 2022 vol. 3 is now available
INFOexchange 2022 volume 3 is now available. The issue includes a message from our Chair, Kelly Adams on the latest developments at CALU including preparations for our fall conference and a new mentorship program as well as an advocacy update from the Chair of the Government Relations Committee, Kate Pal. Also included are two expert articles authored by CALU Tax Advisor, Kevin Wark on Recent CRA interpretations of interest and Insurance transfers to children: Tips and traps. (Members only) Download now
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) ...
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 ...
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 ...
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
Rapport spécial de CALU : Réponses de la table ronde ARC-Finances 2022
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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 (kwark@calu.com) should you have any questions relating to the CRA and Finance responses and related commentary. (Members only) Download the report ...
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
