Section 138.1

Subsection 138.1(1) - Rules relating to segregated funds

Administrative Policy

17 June 1999 External T.I. 9905255 - SEGREGATED FUNDS AND GUARANTEES

Includes a numerical example illustrating the income tax treatment of benefits provided to a policy holder in the form of guarantees under a...

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31 March 1995 External T.I. 9501955 - FOREIGN SEGREGATED FUND POLICIES

A life insurance policy of a non-Canadian insurance company not carrying on business that is held by a non-resident individual after she becomes...

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Articles

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Classification of Trusts for Income Tax Purposes", Chapter 2 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016.

Overview

[U]nlike mutual funds, segregated funds cannot be structured as trusts because a life insurer is prohibited from acting as a trustee in...

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Paragraph 138.1(1)(a)

Administrative Policy

2017 Ruling 2016-0625301R3 - Merger of two related segregated fund trusts

CRA ruled that the s. 107.4 rollover applied to the “transfer” of all the property of one segregated fund to another segregated fund held by...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) merger of two segregated funds held by the same insurer would occur on a s. 107.4 rollover basis 410

Paragraph 138.1(1)(e)

Subparagraph 138.1(1)(e)(i)

Administrative Policy

8 July 2020 CALU Roundtable Q. 4, 2020-0842171C6 - Segregated Funds and 85(1)

S. 39(1)(a)(iii) provides that a taxpayer’s capital gain excludes gain from the disposition of an insurance policy, including a life insurance...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) - Paragraph 85(1.1)(a) an interest in a related segregated fund trust was a capital property 230

Paragraph 138.1(1)(f)

Administrative Policy

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 10, 2021-0896101C6 F - Death of seg. fund policyholder - income allocatio

An individual owns a segregated fund policy in a non-registered account with a life insurance company, and is the annuitant under the policy. The...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) deeming of an amount to be payable for s. 104(24) purposes does not create a legal entitlement to it 214