Opco is the beneficiary of a universal life insurance policy (the "Policy") on the life of its sole shareholder, Mr. A, who is the policyholder. Opco pays the premiums on the Policy. A policy loan is made by the insurer to Mr. A. Is there a shareholder benefit?
CRA indicated that the payment of the premiums gave rise to s. 15(1) benefits, but not the advance of the policy loan.