Articles
Strain, "Life Insurance: An Innovative Financial Instrument", 1993 Conference Report, pp. 35:7-8.
Lengvari, Joshua, "Matters of Life and Death", CA Magazine, August 1995, p. 44
Discussion of continued potential for utilization of life insurance policies as an investment vehicle.
Subsection 306(1)
Administrative Policy
14 May 2019 CLHIA Roundtable Q. 6, 2019-0799101C6 - CLHIA 2019 Conference-Q6 Foreign Exempt Policies
It is unlikely that testing for compliance with Reg. 306(1) will be routinely performed by the insurer for policies issued outside of Canada where...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12.2 - Subsection 12.2(1) - Paragraph 12.2(1)(a) | taxpayer cannot rely on failure of foreign insurer to test exemption | 128 |
26 May 2003 External T.I. 2002-0180455 F - MODIFICATION D'UNE POLICE EXONEREE
Where a life insurance company splits a life insurance policy based on the age of the policyholders at the time the policy was issued, does this...
11 October 2001 External T.I. 2001-0100245 F - POLICE EXEMPTEE ASSUREUR NON-RESIDENT
CCRA noted that although a life insurance policy issued by a non-resident insurer can be an exempt policy when the policyholder immigrates to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) | s. 128.1(1) applicable to life insurance policy of non-resident insurer to a non-resident policyholder’s immigration | 82 |
Paragraph 306(1)(b)
Articles
Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50
Shift to one-year pre-test (p. 719)
[T]he rule now requires only a one-year pre-test. This requires the insurance company to project the...
Subsection 306(3)
Paragraph 306(3)(b)
Articles
Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50
Example of additional exempt test policy where >8% annual increase in death benefit (p. 720)
Example 1
Assume that a life insurance policy is...
Subsection 306(6)
Paragraph 306(6)(b)
Articles
Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50
Redating of exempt test policy where >250% increase in accumulating fund over 3 years (p. 721)
In addition to the so-called 8 percent test,...