An actuary is retained to determine the fair market value of a life insurance policy by an individual to a wholly-owned corporation, and the transferor and transferee split the actuary’s fee. Respecting the treatment of the fee to the transferee, CRA stated:
Under subsection 148(7), the cost to the corporation of its interest in the policy will be equal to the value determined under subsection 148(9). That amount will be included in Element A of the definition of "adjusted cost basis” in subsection 148(9). No adjustment is made to the calculation of the adjusted cost basis under that paragraph to reflect the costs that the corporation has made or incurred to obtain an assessment of the fair market value of the policy.