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Going forward, as CRA gains experience with increased electronic data sources and filing requirements, consideration could be given to conducting a review to reduce or eliminate overlap and duplication where possible. ...

CALU Roundtable- May 2018 Question 3- Subsection 148(8)-Transfer of an insurance policy from a parent to child Background Subsection 148(8) provides for a rollover of a life insurance policy where an interest in the life insurance policy is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the life insured under the policy. ... CRA Response Subsection 148(8) of the Act provides that, if an interest of a policyholder in a life insurance policy (other than an annuity contract) is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of the disposition equal to the adjusted cost basis of the interest immediately before the transfer, and to have been acquired by the person who acquired the interest at a cost equal to those proceeds. ...

CALU- Conference for Advanced Life Underwriting (2004) Question 6 Transfer of a Life Insurance Policy Under Which More Than One Child is Insured Subsection 148(8) provides rollover treatment when a policyholder transfers a life insurance policy to a child of the policyholder for no consideration if a child of the policy or of the transferee is the life insured. ... The father transfers ownership of the policy to his son for no consideration. ...

(B) What are some of the considerations that the legal representative should consider and document when asking for an extension? ... What are some of the considerations that the legal representative should consider and document when asking for an extension? ...

If the adjusted cost base of the trust units held by a beneficiary is nil and if the cost of the goodwill in respect of the business of the trust is nil, will the beneficiary be liable to tax on a total amount of $75,000 in a situation where the trust sells the goodwill for a consideration of $100,000 and distributes that amount to its beneficiary qua income and capital distribution; the amount of $75,000 being composed of an income distribution of $50,000 and of a taxable capital gain of $25,000 resulting from the negative ACB of the trust units after the capital distribution. ... The goodwill is transferred for a consideration of $100,000 and we assume that the other assets do not have any value; On November 30 2008, the trust distributes to X Co, its beneficiary, all the proceeds that it received, being the $100,000 received as consideration for the goodwill. ... Indeed, paragraph 53(2)(h) of the ITA does not apply to an interest in a personal trust that has never been acquired for consideration, or an interest in a trust described in any of paragraphs (a) to (e.1) of the definition "trust" in subsection 108(1) of the ITA. ...

The employee would have an employment benefit under paragraph 6(1)(a) equal to the excess of the FMV of the policy at that time, over the amount of any consideration paid by the employee for the policy. ... The agreed consideration for the sale of the policy is $1. Question Based solely on the above facts, does CRA view the sale of the policy from Corporation A to Individual A to be a non-arm’s length transaction such that subsection 148(7) applies? ... However, Employee B has learned of this and requested that the policy be transferred to her and the company has agreed to do so for no consideration. ...

A person is also a promoter if the person (i) makes a statement or representation that a tax benefit could result from the arrangement if the statement is made in furtherance of the promoting or selling of the arrangement, or (ii) accepts consideration in respect of the arrangement. ... A has acted in a manner described in the definition “advisor” or “promoter” in subsection 237.3(1) of the Act in respect of the sale of the financial product); the terms of the sale of the financial product and the series of transactions; the terms of the financial product; the terms of the consideration received by Ms. ... We note that this response is based on current legislation and does not take into consideration the draft legislative proposals released by the Department of Finance on February 4, 2022. ...

Opco then transferred Asset 2 to Newco in consideration for shares of Newco. ... Opco then transferred shares of Subco2 having an ACB of nil and a FMV of $500 to Newco in consideration for shares of Newco. ...

À cette fin, l'autorité compétente du Canada nous a mentionné qu'elle prendrait en considération tous les faits propres à la situation donnée en vue d'évaluer l'importance des liens que la fiducie entretient avec le Canada par rapport aux États-Unis. En plus des facteurs prévus au bulletin d'interprétation IT-447, Résidence d'une fiducie ou succession, l'autorité compétente canadienne pourrait prendre en considération certains des facteurs suivants: la résidence du constituant, la résidence des bénéficiaires, l'emplacement des biens de la fiducie, la raison pour laquelle la fiducie est établie dans une juridiction particulière, etc. Cette liste ne se veut pas exhaustive puisque les faits de chaque cas peuvent justifier différentes considérations, lesquelles pourraient conduire à différentes conclusions et négociations. ...

17 May 2013 Roundtable, 2013-0481421C6- Transfer of life insurance policy to a retiree CRA Tags 107 148 Principal Issues: (1) Does subsection 148(7) apply when a corporation transfers a life insurance policy to a senior executive officer who is also a shareholder for no consideration? ... The corporation transfers the policy to the individual for no consideration. ... Question B Could the CRA also confirm what its position is with respect to the computation of the ACB, to an individual, of a life insurance policy in the case where: i) an RCA trust holds an insurance policy on the life of the individual ii) the individual is a beneficiary of the RCA trust and is also a shareholder and senior officer of the corporate employer, iii) the individual does not deal at arm's length with the RCA trust, and iv) the custodian of the RCA transfers the policy to the individual for no consideration. ...