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8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6- Return of premiums on death & CDA-- summary under Paragraph (j) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition- Paragraph (j) a refund of premiums on death under a life insurance policy does not entail its disposition A private corporation is the owner and beneficiary of an exempt life insurance policy (with an adjusted cost basis of $90,000) on the life of a shareholder, who dies from, say, suicide or skydiving, which does not void the policy, but instead results in the insurer repaying all premiums ($100,000). ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 4, 2020-0851621C6 F- RRSP or RRIF on death – Joint election-- summary under Subsection 146.3(6.1) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.1) specific bequest of RRIF is treated as passing through the estate’s hands, so that a s. 146.3(6.1) election is necessary Where a RRIF is the subject of a specific bequest made to the deceased annuitant's spouse under a Quebec will and the RRIF proceeds are distributed by the RRIF issuer directly to the surviving spouse, CRA considers that the RRIF proceeds passed through the estate rather than coming directly out of the RRSP, as required under the “designated benefit” definition. ...

15 June 2022 STEP Roundtable Q. 13, 2022-0929381C6- 164(6) – Amending Deceased’s Final T1 Return-- summary under Paragraph 164(6)(e) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(6)- Paragraph 164(6)(e) s. 164(6) amendment must be made through filing an amended return, not a T1 Adjustment Request The conditions for allowing capital losses of a graduated rate estate in its first taxation year to be considered capital losses of the deceased pursuant to s. 164(6) include that an election is filed, and the legal representative amend the deceased’s final T1 return of income. ...

7 October 2022 APFF Roundtable Q. 3, 2022-0942121C6 F- THRP- PRTA – Versement de dividendes imposables-- summary under Subsection 125.7(14.1) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(14.1) there is no adverse CEWS impact of a non-resident parent paying dividends to individuals Regarding the presented proposition that publicly traded companies or their subsidiaries are not entitled to any CEWS grants for the claim period in which dividends were paid to individuals who are holders of common shares, and the presented example of a parent company listed on the Paris stock exchange, with a Canadian subsidiary in Canada and an individual shareholder, which declares a dividend to be paid on March 31, 2022, CRA effectively indicated that the payment of a dividend at the parent level was irrelevant, and there would only be an adverse CEWS impact under the rules in ss. 125.7(2.01) and (14.1) if the Canadian subsidiary itself paid a dividend to an individual. ...

20 June 2023 STEP Roundtable Q. 14, 2023-0967371C6- s.70(6) & Application to Extend-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) requesting an extension of the 36-month vesting period under s. 70(6) What is the process for making a written request to extend the 36-month period under s. 70(6) for the property of the deceased to vest indefeasibly in the surviving spouse or common-law partner or trust, and what should be included in the request? ...

3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 3, 2023-0976921C6 F- CELIAPP- Acquisition d'une quote-part d'une habitation admissible / FHSA- Acquisition of a share of a qualifying home-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership reference to acquiring a qualifying home includes acquiring a co-ownership interest Various conditions in the “qualifying withdrawal” definition in the FHSA rules refer to acquiring a qualifying home. ...

2 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 5, 2023-0978561C6 F- Partnership – distribution of a life insurance police-- summary under Subsection 148(7) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(7) s. 98(2) generally prevails over s. 148(7) Regarding the situation where a partnership held, was the beneficiary of, and paid the premiums for 10 years on, three policies on the lives of each of the three individuals who were its partners and then, pursuant to the partnership agreement, transferred the applicable policy to one of the partners on that member’s withdrawal from the partnership, CRA indicated: [W]here the conditions of subsection 98(2) are satisfied, we are generally of the view that subsection 98(2) would override subsection 148(7) so that the partnership's proceeds of disposition of the life insurance policy would be the FMV of the policy. ...

2 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 5, 2023-0978561C6 F- Partnership – distribution of a life insurance police-- summary under Subsection 248(35) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(35) holding of policy by partnership prior to its distribution to partner does not count towards the latter’s holding period A partnership held, was the beneficiary of and paid the premiums for 10 years on, three policies on the lives of each of the three individuals who were its partners and then, pursuant to the partnership agreement, transferred the applicable policy to one of the partners (Individual C) on that member’s withdrawal from the partnership. ...

2 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 5, 2023-0978561C6 F- Partnership – distribution of a life insurance police-- summary under Subsection 98(2) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(2) disposition of distributed life insurance policy at FMV pursuant to s. 98(2), rather than s. 148(7) applying Regarding the situation where a partnership held, was the beneficiary of, and paid the premiums for 10 years on, three policies on the lives of each of the three individuals who were its partners and then, pursuant to the partnership agreement, transferred the applicable policy to one of the partners on such withdrawal of “Individual C” from the partnership, CRA indicated: [W]here the conditions of subsection 98(2) are satisfied, we are generally of the view that subsection 98(2) would override subsection 148(7) so that the partnership's proceeds of disposition of the life insurance policy would be the FMV of the policy. ...

7 May 2024 CALU Roundtable Q. 4, 2024-1007061C6- Shared Ownership & Charitable Gift-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts 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 After referring to the position in IT-244R3 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 and the donee has become the registered beneficiary of the policy, CRA stated that “split-dollar” or other shared ownership arrangements are beyond the scope of the CRA's 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. ...