A corporate owner and beneficiary of a life insurance policy receives a death benefit in the amount of $850,000, less a policy loan of $150,000 ($1,000,000 - $150,000) in accordance with the terms of the life insurance policy. Regarding the ACB immediately before death, CRA stated:
[T]he ACB of the life insurance policy for CDA purposes is $50,000. The reduction of the benefit payable at death by the amount of the policy loan at death is not a repayment of a policy loan described in Element E of the definition of ACB in subsection 148(9). This is because the calculation of the ACB for purposes of the CDA definition is made immediately before death. Furthermore, Element E of the ACB requires consideration of policy loans repaid prior to the time of the ACB calculation.