CRA confirms its policy in IT-244R3 regarding gifts of a life insurance policy to a charity, but does not articulate any extension of this policy to split dollar arrangements

IT-244R3 indicated that a gift by an individual of a life insurance policy to a registered charity is considered to be a gift for purposes of s. 118.1 provided that the policy has been absolutely assigned to the donee, who becomes the registered beneficiary. CRA stated that “split-dollar” or other shared ownership arrangements are beyond the scope of its position in IT-244R3. 2003-0004315 indicated that there may be arrangements that could result in a charitable gift for purposes of s.118.1 within the spirit of the split-receipting rules but such a determination can only be made on a case-by-case basis.

Neal Armstrong. Summary of 7 May 2024 CALU Roundtable Q. 4, 2024-1007061C6 under s. 118.1(1) – total charitable gifts.