Submissions and Presentations

CALU submission to Finance on LI in LI trusts

CALU submission to request an amendment to the Income Tax Act in response to Canada Revenue Agency (CRA) interpretations relating to the ownership of life insurance by a life interest trust. The CRA has taken the position that, where the terms of a trust permit the trustee to fund a life insurance policy, the trust will not meet the conditions set out in subparagraph 70(6)(b)(ii) or 73(1.01)(c)(i) to be a spousal or common-law partner trust. In particular, the CRA’s view is that if the terms of the trust permit the payment of premiums by the trust, this can result ...

November 17, 2022|Categories: Submissions and Presentations|

CALU submission on Proposed Notifiable Transaction Rules

CALU submission on Proposed Notifiable Transaction Rules recommending that the exclusion provided to financial institutions under draft subsection 237.4(6) not be part of the final notifiable transaction legislation. This would ensure these financial institutions play a similar role in reporting to the CRA, as compared to other financial and advisory organizations, by ensuring that proper reporting is being provided by the employer in respect any advisory services provided by their employees that relate to a notifiable transaction. Alternatively, the exclusion in draft subsection 237.4(6) should be extended to all employees of these financial institutions, subject to the same limitations ...

November 2, 2022|Categories: Submissions and Presentations|

CALU request for technical interpretation from CRA on jointly owned policies

CALU submitted a request for interpretation to CRA relating to the application of subsection 148(7) of the Income Tax Act to the joint owners of a life insurance policy on the death of one of the joint owners. Provided at the end of the submission is more information on the legal and tax nature of joint ownership with right of survivorship and tenancy in common, as well as a discussion of the property law underpinnings of life insurance as a “chose in action”. View the submission

July 20, 2022|Categories: Submissions and Presentations|



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