A CCPC is the policyholder of a critical illness policy respecting its sole shareholder where either the shareholder is the beneficiary of the benefit, or the benefit is payable to the policyholder.
CCRA indicated that in both cases, the premiums paid by the corporation would not be deductible to it by virtue of ss. 18(1)(a) and/or (b), and that there would be a taxable s. 15(1) benefit to the shareholder from such payment of premiums in the second situation, but not the first.