Principal Issues: At the 2014 CALU Conference, the CRA indicated that paragraph 20(1)(bb) does not apply to allow a deduction for fees paid by a taxpayer for advice on acquiring or disposing of or for services in respect of the administration or management of segregated fund policies. Will the CRA reconsider this position?
Position: Our position remains unchanged.
Reasons: The underlying legal nature of a segregated fund policy is that of a contract of insurance, which is, in our view, not a security of the taxpayer for purposes of paragraph 20(1)(bb).