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Moving to Canada with foreign life insurance

What are the tax consequences of moving to Canada with foreign life insurance?

Divisive reorganizations and life insurance – Breaking up is hard to do

When it comes to divisive reorganizations, life insurance can be a challenging asset to deal with from a tax point of view. When putting corporate owned life insurance in place, it is important to consider which corporation in a corporate…

Capital gains inclusion rate change – Back to where we started

Deferred implementation of proposed changes to the capital gains inclusion rate to January 1, 2026 brings us back to where we always were. Funding estate tax liabilities should remain in focus.

Charitable gift extension – Questions answered

Questions have been answered regarding the extent of the promised tax measure that would recognize gifts to charity made until February 28, 2025, for the 2024 tax year. Draft legislation was released.

Capital gains inclusion rate change – To be or not to be?

Here is our take on the recent political and administrative events that have unfolded to start 2025 focusing on the capital gains inclusion rate change that is not yet law.

Joint last-to-die life insurance – Food for thought

When is joint last-to-die life insurance the right fit? And when is it not? Here are some considerations.

The nuts and bolts of interest deductibility and leveraged life insurance – A primer

For a review of interest deductibility in the context of leveraged life insurance.

Trust rollout of life insurance – Confirmed in writing

The CRA’s long-standing position allowing a rollout of a life insurance policy from a trust has been confirmed in writing at the recent APFF Conference.

The quest for corporate beneficial ownership information – Where it’s at and where it’s going

Transparency of corporate beneficial ownership information is required to be publicly available for companies incorporated under the Canada Business Corporations Act. For an update on corporate beneficial ownership in Canada.

A business succession story – As told by the Tax Court

A tax case chronicles the story of a family business succession with a happy ending.

CRA Guidance on Mandatory Disclosure – Contingent fees

CRA guidance on mandatory reporting says referral fees in respect of estate freeze transactions and the acquisition of life insurance do not require mandatory reporting. Positive for mainstream non-aggressive tax planning connected to life insurance BUT.

The rundown on in-kind charitable gifts of life insurance and some recent clarifications

For considerations and rules relating to in-kind gifts of life insurance and an update on recent, specialized clarifications from the 2024 CALU CRA Roundtable and the August 12, 2024 draft legislation concerning life insurance gifts.

Technical amendment expands the time frame for post-mortem capital loss carry-back planning

We welcome the August 12, 2024 technical amendment to subsection 164(6) which extends the time frame for post-mortem capital-loss carry back planning.

Demystifying life insurance claims – How instant is “instant liquidity”?

One of the primary benefits of life insurance is its “instant liquidity”. The payment of life insurance claims can be surprisingly prompt after the claim has been submitted. For what needs to happen for it to go as smoothly as…

Legislative loose ends

For an update on enacted tax legislation and some of the loose ends we’ve been following.

Roll-over of life insurance to a child – it’s a thing!

For a primer on the ins and outs of the rollover for transfers of a life insurance policy to a child.

Post-mortem planning – Some updates

For an update on recent post-mortem planning items and a reminder that life insurance can fund tax liabilities arising in respect of owning private company shares on death.

Capital gains inclusion rate details – Thinking about the long term

The details of the capital gains inclusion rate increase are out. No big surprises. Think beyond June 25 and asses the long term impacts. Your clients might need more insurance.

The increased capital gains inclusion rate – Quantifying the hit

The proposed new capital gains inclusion rate will result in a difference of 8.56 percentage points. Is the actual impact 8.56% or is it 32%?

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.
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ABOUT THE AUTHOR:

Florence is a co-editor of the Canadian Taxation of Life Insurance, currently in its 12th edition and Editor-in-Chief of Insurance Planning, both published by Thomson Reuters. She is a member of the Canadian Tax Foundation, Society of Trust & Estate Practitioners, Estate Planning Council of Toronto, and the Conference for Advanced Life Underwriting. Florence is a frequent speaker and author at these and many other organizations.

If you wish to reach Florence, please email florence@tompkinsinsurance.com

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