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Ownership
Ownership transfer - partnerships
There is no tax-deferred rollover for the transfer of a life insurance policy from a partner to a partnership. The same disposition...

PPI
Apr 231 min read
Corporate ownership
Advance planning is the best way to avoid what can be onerous tax consequences when transferring a life insurance policy from an...

PPI
Apr 231 min read
Passive investment rules
The passive investment income rules were introduced in the 2018 federal budget. The rules result in a reduction in the small business...

PPI
Apr 221 min read
Impact of corporate owned insurance on share valuations
Owning insurance in a corporation must be considered in valuing the shares of a company. Here are two common examples:

PPI
Apr 201 min read
CDA Tax considerations
The capital dividend account (“CDA”) is a notional account that exists to maintain a fundamental part of the tax system in Canada – that...

PPI
Apr 196 min read
Separating corporate owner and beneficiary
Despite the change to the CDA calculation to track the ACB to the beneficiary, there are still important reasons to have one corporation,...

PPI
Apr 182 min read
Ownership transfer - corporation to shareholders and employees
Any gain arising when proceeds exceed the ACB is an income gain and is treated like interest income to the corporation If a shareholder...

PPI
Apr 172 min read
Ownership transfer - shareholder to corporation
When the FMV is greater than the CSV or ACB, there is no requirement for the shareholder to receive FMV consideration on the transfer; ...

PPI
Apr 161 min read
Ownership transfer - amalgamation & windup
There are special provisions that will apply to the transfer of policies where corporations are amalgamated or wound up. For...

PPI
Apr 151 min read
Ownership transfer – between sister corporations
When a policy is transferred between two sister corporations that are not dealing at arm’s length, the proceeds...

PPI
Apr 141 min read
Corporate rollover rules
A corporate rollover is not permitted: Unlike most kinds of other property, a life insurance policy cannot be transferred to a...

PPI
Apr 121 min read
Death of an owner
If a policyowner dies who is not the insured, there is a disposition of a life insurance policy when a policy is transferred unless an...

PPI
Apr 111 min read
Policy splitting in the event of divorce
When there is a joint last to die policy and the spouses divorce, it is unlikely that the policy can be divided into two single policies...

PPI
Apr 101 min read
Successor owner & joint owner at death
A joint last-to-die policy is usually on the lives of two spouses. If one spouse owns the policy the other can be named...

PPI
Apr 91 min read
Personally-owned rollover rules
A tax-deferred policy rollover is permitted, both inter-vivos and on death: If the transfer of the policy is to the policyholder’s spouse...

PPI
Apr 81 min read
Ownership transfers – to and from trusts
Where an individual gifts a life insurance policy to a trust, the proceeds would be the greater of CSV and ACB since no consideration...

PPI
Apr 71 min read
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