4 May 2010 CALU Roundtable, 2010-0359421C6 - Shareholder's benefit and life insurance -- summary under Subsection 246(1)

S. 246(1) could apply where a corporation (Parentco) holds a life insurance policy for which it pays the premiums and designates its subsidiary (Subco) as the beneficiary. It would be necessary to determine, with all the relevant documentation, whether the reimbursement of premiums should be included in the income of the corporate life insurance policyholder (Parentco) under s. 9 or 12(1)(x) where its subsidiary (Subco) was named as the irrevocable beneficiary of the life insurance policy and reimbursed Parentco for the premiums paid by Parentco.