7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 1, 2016-0651771C6 F - Critical Illness Insurance -- summary under Subsection 15(1)

CRA noted respecting the transfer for no consideration of a critical illness insurance policy by Opco (which was the policyholder, beneficiary and had paid all the premiums) to its shareholder (so that the shareholder became the holder and beneficiary) to Holdco, that although no capital gain would arise on the transfer to Opco, under s. 15(1) “the value of the benefit could correspond to the FMV of the policy.”