
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…

October 26, 2023
Looking back and looking forward
Over the past 30 years the acceptance and deployment of life insurance within estate and business succession planning has blossomed. In large part, we attribute this increased utilization to a greater understanding of the unique…