CRA has indicated that where a corporation transfers an interest in a life insurance policy of which it is the owner to an individual who is its sole shareholder, there will be a s. 15(1) benefit equal to the excess of the fair market value of the interest in the life insurance policy over the consideration paid. What about a situation where an individual is the sole shareholder of two corporations and an interest in a life insurance policy is disposed of by one of the corporations to the other?
CRA responded:
[I]t is possible that the transferor corporation may be impoverished as a result of the transaction described above. In such a case, to the extent that it is shown that, under the terms of the transaction, the transferor corporation confers a benefit on the sole shareholder, subsection 15(1) would apply to require the individual to include in income the value of the benefit conferred.