After indicating that the acquisition by a shareholder of an interest in a corporate life insurance policy for less than the fair market value (FMV) of that interest would engage s. 15(1) to the extent of the excess of the FMV of the interest in the life insurance policy over the consideration paid, CRA stated:
The FMV of an interest in a life insurance policy is not generally equivalent to its cash surrender value. The age and health of the insured, the value of the accumulation fund, the cash surrender value and the amount of premiums paid at the date of transfer are all factors to be considered in determining the FMV.