What is the value of the benefit under s. 15(1) where a corporation changes the beneficiary of a life insurance policy on the life of its shareholder (Mr. A) from its subsidiary to the spouse of Mr. A, and Mr. A does not have more than a few months to live? CRA responded:
[D]epending on the circumstances, the CRA may consider the amount of premiums that would be payable if Shareholder A entered into a new life insurance policy at the time of the change in beneficiary, the fair market value of the insurance policy or the total amount that the insurer will pay by virtue of the policy.