Words and Phrases - "contemplated shareholder"

A corporation which already offers group insurance (life, health and disability) to all its employees with the premiums paid by them, has created a supplementary disability insurance plan for two of its executive employees, one of whom is the majority shareholder. Would this constitute a group insurance plan and would the premium paid by the employer be taxable benefits to the two executives?

After noting that there would be no taxable benefit under s. 6(1)(a) from the employer's payment of the premiums if this arrangement qualified as a group plan described in s. 6(1)(a)(i), CRA went on to note that its general presumption “that an employee shareholder receives benefits or allowances in their capacity as a shareholder if they can significantly influence the policies of the corporation” can be rebutted if “all employees of the corporation are entitled to the benefit” or if all employees are shareholders or related to a shareholder and the benefit “is comparable (in nature and amount) to the benefits … generally offered by corporations of the same size to non-shareholder employees whose services and responsibilities are similar.” Here there would be a s. 15(1) benefit if the benefit from the premium payments “had been granted to them because of their status as shareholders or contemplated shareholders” (i.e., “a person to whom a benefit is conferred by the corporation because they are being considered to become a shareholder of the corporation.”)