7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 9, 2016-0651801C6 F - Assurance-vie à assurés multiples-110.6(15) -- summary under Small Business Corporation

S. 110.6(15)(a) provides that a shareholder’s shares are to be valued for various listed purposes including the “small business corporation” definition on the basis that a life insurance policy owned by the corporation on the shareholder’s life is to be valued at its cash surrender value. CRA has confirmed that 110.6(15)(a) applies even where the corporate policy covers lives other than that of the shareholder, e.g., the payout occurs on the death of both the shareholder and a key employee, or on the survivor of the shareholder and his spouse.