CRA stated:
In factual situations similar to the Innovative Installation case, the CRA will apply the position adopted by the Court in that case.
Consequently, in a situation where a corporation can demonstrate that life insurance proceeds that were paid directly to a financial institution have reduced its debt to the financial institution, the life insurance proceeds will be considered as "received" by that corporation for the purpose of applying subparagraph (d)(ii) of the definition of CDA … .