Section 148

Subsection 148(2) - Deemed proceeds of disposition

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 148(2)(e)

Subsection 148(4.01)

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

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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 356

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 69 - Subsection 69(5) s. 69(5) generally prevails over s. 1487 106

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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 416
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 203

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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) 83

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

15 February 1995 T.I. 943386 (C.T.O. "Disposition of Life Insurance Policy on Death")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 148(8.1) - Inter vivos transfer to spouse

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

Subsection 148(9) - Definitions

Adjusted Cost Basis

See Also

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Proceeds of Disposition general discussion re corporate owned policy 180

23 March 1992 External T.I. 5-911717 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Disposition

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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 246

25 February 2003 External T.I. 2002-013889 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

August 1994 Memorandum 940797 (C.T.O. "Deferred and Prescribed Annuity Contracts")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

31 January 1994 T.I. 933643 (H.A.A. 5720-1) (C.T.O. "Disability Benefitting Group Insurance Policy:)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 March 1994 T.I. 933379 (C.T.O. "Mortgage Insurance Cashback Program")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Policy Loan

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Proceeds of Disposition

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis general discussion re corporate owned policy 186

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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Disposition disposition where change going to root of policy 65