OPCO, which was the policyholder and holder of an insurance policy on the life of its sole shareholder (A), whose wife (B) was the beneficiary, paid the annual premiums on the policy,
The Directorate indicated that the taxable benefit arose as and in the amount of the premiums that were so paid, and that the payment of the DEATH benefit to B under the policy did not give rise to a s. 15(1) benefit. The Directorate further indicated that Audit should consider reassessing beyond the normal reassessment period based on s. 152(4)(a)(i).