Section 148

Subsection 148(1)

See Also

Andersen v. The Queen, 2020 TCC 51 (Informal Procedure)

The taxpayers terminated life insurance policies for personal purposes, and were ultimately reassessed to include in their income the gross...

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Tax Topics - General Concepts - Onus assessments vacated for failure to assume the policiers' ACB 286

Administrative Policy

7 October 2011 Roundtable, 2011-0408351C6 F - Honoraire d'évaluation d'une police d'assurance

An actuary is retained to determine the fair market value of a life insurance policy by an individual to a wholly-owned corporation, and the...

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Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis - Element A valuing the FMV of acquired property not considered to be part of its cost 126

Subsection 148(2) - Deemed proceeds of disposition

Administrative Policy

19 March 1992 T.I. (Tax Window, No. 18, p. 21, ¶1822)

Where a policy holder provides standing instructions to make partial withdrawals from his savings account this, by itself, will not constitute the...

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Paragraph 148(2)(b)

Administrative Policy

6 January 2005 Internal T.I. 2004-0100241I7 F - Imposition des rentes au décès

Regarding the taxation of prescribed and non-prescribed annuity contracts on the death of the holder and annuitant (the "Annuitant"), the...

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Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Proceeds of Disposition - Paragraph (d) disposition gain based on accumulating fund 140

Paragraph 148(2)(e)

Articles

Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50

Impact of death benefit on adjusted cost basis of a multi-life policy (pp. 730-1)

New paragraph 148(2)(e)…applies to a situation where an...

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Subsection 148(4.01)

Articles

Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50

Deeming of partial surrender of policyholder’s interest so as to reduce policy loan to be loan repayment followed by partial surrender (pp....

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Subsection 148(7) - Disposition at non-arm’s length and similar cases

Administrative Policy

5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 1, 2018-0761521C6 F - Life insurance policy as share redempt. proceeds

2017-0690331C6 found that a dividend-in-kind by a subsidiary to its parent of a life insurance policy would result in proceeds of disposition to...

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14 May 2015 CLHIA Roundtable Q. 5, 2015-0573821C6 - Safe income

Prior to a sale by Holdco of all the shares of Opco to an arm's length purchaser, Opco will transfer its interest in the Policy on the life of Mr....

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) policy premiums reduce SIOH only if they do not increase CSV 374

14 May 2015 CLHIA Roundtable, 2015-0573841C6 - 2015 CLHIA Roundtable – Winding-up and ACB

At the 2005 CALU Roundtable (2005-0116631C6), the CRA indicated that s. 69(5) would likely take precedence over s. 148(7) on the wind-up of a...

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(5) s. 69(5) generally prevails over s. 1487 112

27 May 2009 External T.I. 2008-0303971E5 F - Transfer of a life insurance policy

An individual is the owner of, and the insured under, a whole life insurance policy having an adjusted cost basis of $45,000, a cash surrender...

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5 June 2007 Internal T.I. 2007-0237291I7 F - Disposition d'une police d'assurance-vie

CRA indicated that it considers a partnership to be a person for income-computation purposes, so that s. 148(7) would apply to a gift of policies...

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6 October 2006 Roundtable, 2006-0197211C6 F - Transfert de police d'ass-vie entre sociétés

S. 148(7) applies where a corporation whose capital stock is wholly owned by an individual transfers an interest in a life insurance policy of the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) s. 15(1) could apply to the individual shareholder of Aco and Bco where Aco transfers an insurance policy at an undervalue to Bco 163

21 November 1991 T.I. (Tax Window, No. 13, p. 20, ¶1607)

Where a taxpayer, who owns a 1/4 interest in a life insurance policy transfers his interest to the other three owners with whom he does not deal...

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Articles

David Louis, Michael Goldberg, "Life Insurance: Exploring the Corporate Edge - Part II", Tax Topics No. 1682, June 3, 2004, p. 1.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 18

Paragraph 148(7)(a)

Administrative Policy

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 9, 2017-0705231C6 F - Gift of a Life Insurance Policy and Subrogated Own

The will of Mr. Donor provided for a gift of his life insurance policy on the life of his daughter to a private foundation. On his death, the...

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Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts - Paragraph (c) - Subparagraph (c)(i) - Clause (c)(i)(C) claim in terminal return for charitable gift made by estate under individual’s will 430
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts - Paragraph (c) - Subparagraph (c)(i) - Clause (c)(i)(A) no guidance on whether designating a charity as a contingent policyholder generates a charitable credit 211

18 May 2017 Roundtable, 2017-0690331C6 - CLHIA Q2 Dividend in kind transfer of policy

Mr. X holds the preferred shares of Opco with a redemption value of $1 million, and adjusted cost base and paid-up capital of $1, and a family...

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7 June 2017 External T.I. 2016-0671731E5 F - Transfer of life insurance policy by dividend in kind

Holdco, which was the holder and beneficiary of a life insurance policy on the life of its sole shareholder, transferred the policy to him as a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 52 - Subsection 52(2) proceeds and cost of distributed life insurance policy determined under s. 148(7) rather than s. 52(2) 87

7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 3, 2016-0651761C6 F - Transfer of a Life Insurance Policy

(a) Mr. X, who has for a number of years been the policy holder of a term life insurance policy (for 100 years) without a cash surrender value...

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Paragraph 148(7)(b)

Administrative Policy

14 May 2019 CLHIA Roundtable Q. 2, 2019-0799051C6 - 2019 CLHIA Roundtable - 148(7) questions

As a result of employee B no longer being considered to be a key employee, her employer (Corporation A) transfers its “key person” permanent...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) s. 6(1)(a) applied to transfer of life insurance policy to employee at an undervalue, notwithstanding the application of s. 148(7) 171

Subsection 148(8) - Idem [Disposition at non-arm’s length and similar cases]

Administrative Policy

8 May 2018 CALU Roundtable Q. 3, 2018-0745831C6 - Subsection 148(8) transfer

After referencing inter alia 2004-0065441C6, which indicated that an s. 148(8) rollover would not apply to a transfer of a life insurance policy...

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5 June 2013 External T.I. 2013-0481381E5 - Transfer of Life Insurance Policy

In confirming that the transfer of a life insurance policy jointly owned by the parents to their adult son whose life is insured under the policy...

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15 February 1995 External T.I. 9433865 - DISPOSITION OF LIFE INSURANCE POLICY ON DEATH

S.148(8) does not apply where, on the death of a policyholder, the policy is transferred to the policyholder's child under the terms of the will...

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11 July 1989 T.I. (Dec. 89 Access Letter, ¶1059)

The rollover is not available on the transfer of a life insurance policy from a husband who is the basic life insured to his wife who was the...

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Subsection 148(8.1) - Inter vivos transfer to spouse

Administrative Policy

10 December 1992 Memorandum (Tax Window, No. 27, p. 8, ¶2339)

Where a taxpayer has elected not to have s. 148(8.1) apply, s. 148(7) will apply. After the passage of Bill C-92, s. 148(8.1) will apply to a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(8.2) 40

Subsection 148(8.2) - Transfer to spouse at death

Administrative Policy

10 December 1992 Memorandum (Tax Window, No. 27, p. 8, ¶2339)

Where an election is made not to have s. 148(8.2) apply, s. 148(7) will not apply because of the exclusion for dispositions deemed to occur...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(8.1) 26

Subsection 148(9) - Definitions

Administrative Policy

4 April 2005 External T.I. 2005-0110941E5 F - Transfert d'une police d'assurance-vie

After indicating that the acquisition by a shareholder of an interest in a corporate life insurance policy for less than the fair market value...

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) factors relevant to determining FMV of life insurance policy 117

Adjusted Cost Basis

See Also

Kratochwil v. The Queen, 2012 DTC 1084 [at 2917], 2012 TCC 45

The taxpayer, upon redemption of his life insurance policy, was unsuccessful in asserting that his adjusted cost basis was equal to the entire...

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Administrative Policy

3 June 2014 External T.I. 2014-0524031E5 - Life insurance policy disposition

[T]he net cost of pure insurance (the "NCPI")… represents the cost the policyholder paid to be covered by insurance during the time he or she...

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18 February 2014 External T.I. 2013-0515011E5 - Life insurance premiums and policy loan

A corporate policyholder and beneficiary of an exempt universal life policy on the life of one of its key shareholder pays the premiums on the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Proceeds of Disposition general discussion re corporate owned policy 192

19 September 2006 External T.I. 2006-0170861E5 F - Contrat de rente différé et perte courue

In the course of a general response to a question as to which insufficient facts were provided, CRA stated:

Subsection 148(9) defines the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 307 - Subsection 307(1) - Paragraph 307(1)(b) overview of Reg. 307(1)(b) 235

23 March 1992 External T.I. 5-911717

Where one private company is the beneficiary of a life insurance policy taken out by a second holding company on the life of that second company's...

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12 November 1991 T.I. (Tax Window, No. 13, p. 5, ¶1592)

Where an individual owns a life insurance policy and pays the premiums, there will be no addition to the corporation's adjusted cost basis of the...

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Element A

Administrative Policy

7 October 2011 Roundtable, 2011-0408351C6 F - Honoraire d'évaluation d'une police d'assurance

An actuary is retained to determine the fair market value of a life insurance policy by an individual to a wholly-owned corporation, and the...

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(1) no deduction from gain for disposition expenses 110

4 May 2010 Roundtable, 2010-0359401C6 - Rebate Paid by an Advisor to a Policyholder

In certain provinces, a licensed insurance advisor is permitted to pay a portion of the commission earned as a "rebate" to a client purchasing an...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) insurance policy premium rebate generally deductible by insurance advisor payor and included under s. 12(1)(x) in client’s income 108

Disposition

Administrative Policy

APFF Financial Strategies and Instruments Roundtable, Q.2

An individual owning a policy on that individual’s life with coverage of $1 million, a cash surrender value (“CSV”) of $250,000 and an...

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17 February 2016 External T.I. 2015-0608261E5 - Splitting of a Multiple Life Insurance Policy

Respecting the exercise by a policyholder of a contractual right to split a universal life insurance policy covering two lives into two policies,...

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Words and Phrases
disposition
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(10) - Paragraph 148(10)(d) s. 148(10)(d) does not apply to the exercise of a right to split an insurance policy 256

25 February 2003 External T.I. 2002-0138895 - LOAN TO TERMINALLY ILL POLICYHOLDER

While not legally obligated to provide funding to terminally ill policyholders with a life expectancy of less than 24 months, life insurers are...

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27 June 1994 Internal T.I. 9407976 - DEFERRED AND PRESCRIBED ANNUITY CONTRACTS

Re: whether the conversion of a deferred annuity contract into a prescribed annuity contract would constitute a disposition of the deferred...

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1 November 1994 Internal T.I. 94234170 F - CBR Assurance-vie

A rider to a term life insurance policy amended the policy (in a manner not contemplated in the original policy) to provide that the premiums...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition amending policy to reduce premiums and insured amount was not a disposition 56

31 January 1994 External T.I. 9336435 F - Disability Benefit and Group Insurance Policy

An amendment to a group insurance policy to pay special disability benefits either as an advance or as a claim in itself would not result in a...

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19 March 1992, T.I. 920085 (April 1993 Access Letter, p. 150, ¶C144-206)

The furnishing of outstanding instructions or the making of an election by a policyholder with respect to future withdrawals would not normally...

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9 March 1994 External T.I. 9333795 F - Mortgage Insurance Cashback Program

A payment received by a policyholder under a mortgage life insurance policy equal to 10 years of premiums paid under the policy will be considered...

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Paragraph (d)

Administrative Policy

19 November 2009 External T.I. 2007-0257251E5 F - Assurance-vie

If a corporation which is the owner and beneficiary of a life insurance policy changes the beneficiary to its subsidiary, does this change result...

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Words and Phrases
operation of law
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(10) - Paragraph 148(10)(d) designation of a different beneficiary does not entail a disposition 132
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) s. 15(1) benefit where sub is policyholder and premium payer and parent is beneficiary – but not for reverse 223
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) CDA addition to beneficiary not reduced by ACB of policy to the different policyholder - but s. 246(1) or 245(2) germane 195

Paragraph (h)

Administrative Policy

30 November 2006 External T.I. 2006-0191541E5 F - Primes d'assurance-vie et d'assurance-invalidité

A business receives a loan from a financial institution that requires the borrower to take out a disability insurance policy to secure the loan. ...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) premiums on life insurance policy required by lender deductible even though loan government-guaranteed, but premiums on lender-required disability policy not deductible 163
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures premiums on disability policy required by lender are capital expenditures 80
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) guarantee fee does not include premiums on lender-required insurance policy 75
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (j) tax free receipt of life insurance proceeds by lender on policy required by it of the borrower 44

Paragraph (j)

Administrative Policy

8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6 - Return of premiums on death & CDA

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...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) a refund of premiums on death under a life insurance policy can increase the CDA of the corporate owner 262

30 November 2006 External T.I. 2006-0191541E5 F - Primes d'assurance-vie et d'assurance-invalidité

A business receives a loan from a financial institution that requires the borrower to take out a life insurance policy to secure the loan. CRA...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) premiums on life insurance policy required by lender deductible even though loan government-guaranteed, but premiums on lender-required disability policy not deductible 163
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures premiums on disability policy required by lender are capital expenditures 80
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) guarantee fee does not include premiums on lender-required insurance policy 75
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (h) tax free receipt of disability insurance proceeds by lender on policy required by it of the borrower 44

Policy Loan

Administrative Policy

3 July 1991 T.I. (Tax Window, No. 5, p. 15, ¶1333)

A loan made by an insurance company to a policy holder under a formal agreement similar to that used by a bank or trust company nonetheless would...

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Proceeds of Disposition

Administrative Policy

18 February 2014 External T.I. 2013-0515011E5 - Life insurance premiums and policy loan

A corporate policyholder and beneficiary of an exempt universal life policy on the life of one of its key shareholder pays the premiums on the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis general discussion re corporate owned policy 194

9 July 2012 External T.I. 2012-0438751E5 F - Police d'assurance-vie

Does a taxpayer have to include an amount in computing income when settling the taxpayer's life insurance policy at age 65 (before death)? In...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 237 - Subsection 237(1.1) provision of SIN by holder of matured policy to insurer is required 98

Paragraph (b)

Administrative Policy

30 May 2006 Internal T.I. 2006-0175401I7 F - Assurance-vie donnée en garantie

A corporation acquires a universal life insurance policy on the life of its shareholder, with the amount of the insurance coverage and the cash...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) shareholder benefit where corporate universal life policy is pledged for shareholder loan, with loan plus accumulated interest repaid with cash surrender value of policy on the shareholder’s death 278

Paragraph (d)

Administrative Policy

6 January 2005 Internal T.I. 2004-0100241I7 F - Imposition des rentes au décès

Regarding the taxation of a non-prescribed annuity contracts on the death of the holder and annuitant (the "Annuitant") which is not subject to a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(2) - Paragraph 148(2)(b) no disposition of PAC under s. 148(2)(b) – but disposition if estate elects to commute 111

Subsection 148(10)

Paragraph 148(10)(d)

Administrative Policy

17 February 2016 External T.I. 2015-0608261E5 - Splitting of a Multiple Life Insurance Policy

The taxpayer is the policyholder of a universal life insurance policy providing life insurance coverage on the lives of the taxpayer and the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Disposition disposition where change going to root of policy 67

19 November 2009 External T.I. 2007-0257251E5 F - Assurance-vie

If a corporation which is the owner and beneficiary of a life insurance policy changes the beneficiary to its subsidiary, does this change result...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (d) disposition by operation of law if there is a new contract 162
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) s. 15(1) benefit where sub is policyholder and premium payer and parent is beneficiary – but not for reverse 223
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) CDA addition to beneficiary not reduced by ACB of policy to the different policyholder - but s. 246(1) or 245(2) germane 195