May 1, 2024
Alternative minimum tax – Where are we now?
Life insurance is a unique asset that has many favourable tax characteristics. In general, these characteristics are not in and of themselves a problem for AMT.
April 18, 2024
2024 Federal budget – Reflections on the increase to the capital gains inclusion rate through an insurance lens
By now you’ve read the 2024 Federal Budget summaries and digested some of the impacts. Here is what we think about the capital gains inclusion rate changes, looking through a distinctly insurance-focused lens.
April 10, 2024
Roll-out of life insurance policy from a trust – Undisturbed
Prior CRA commentary regarding the roll out to a capital beneficiary of life insurance at cost is undisturbed by recent commentary relating to the transfer of a life insurance policy as a dividend in-kind via…
March 27, 2024
The new GAAR is already getting warmer
More good news from the CRA on the new GAAR. Common tax and estate planning transactions that were not GAAR-able before are not going to be GAAR-able now.
March 13, 2024
Post-mortem pipelines under the new GAAR are OK
The CRA has confirmed that it does not see post-mortem pipeline planning as a misuse or abuse under the new GAAR and will continue to issue favourable rulings. Life insurance in conjunction with post-mortem pipeline…
February 28, 2024
Avoiding the 21-year rule? – Be notified
Certain tax planning to avoid the 21-year rule must be reported to the CRA and in their view, subject to GAAR. Consider using life insurance to solve for problems this planning is meant to address.
January 31, 2024
Holdco and Sisterco owners of life insurance with Opco as beneficiary results in shareholder and indirect benefits
In the case of Gestion M.-A. Roy Inc. et al, the Federal Court of Appeal affirmed the reasoning of the Tax Court to include the amount of premiums paid by Opco in respect of policies…
January 17, 2024
Imperfect conduit – Transfer of a life insurance policy as a dividend-in-kind via a trust
Trusts are not perfect conduits. Dividends received in-kind by a connected corporation that is a beneficiary of a trust maintain their character as inter-corporate dividends but on the disposition of the property itself, differences in…
December 14, 2023
Tax Legislation tabled – Some highlights
Bill C-59 implementing many measures from the 2023 Federal Budget is in progress. Here are our comments on some of the highlights.
