29 December 1989 Ruling 58841 F - Group Sickness or Accident Insurance Plan

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

December 29, 1989

19(1)

This is in reply to your letter dated October 4, 1989 with respect to a group sickness or accident insurance plan (the "Plan") as contemplated in subparagraph 6(1)(a)(i) of the Income Tax Act (the "Act").  All statutory references are to the Act unless otherwise stated.

24(1)

While the income tax implications with respect to any particular arrangement can only be determined after consideration of the specific facts we are able to provide you with the following general comments.  We also refer you to the Department's Interpretation Bulletins IT-227R, IT-301 and IT-428.

The survivor benefit received by the spouse or child of the employee would not ordinarily be included in their income pursuant to paragraph 6(1)(f).  It is likely, however, that the amount of the survivor benefit would be taken into account in the calculation of the recipient's "death benefit" with the meaning of subsection 248(1).  The amount of the death benefit, if any, so determined would be included in the recipient's income by virtue of subparagraph 56(1)(a)(iii).

While we hope our comments are of assistance to you they do not constitute an advance tax ruling and therefore are not binding on the Department in respect of a specific situation.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate