July 31, 2024
Legislative loose ends
For an update on enacted tax legislation and some of the loose ends we’ve been following.
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…
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 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…
