Regarding the availability of the s. 6(1)(a)(i) exclusion regarding premiums paid by corporations for individual critical illness policies provided to senior executives (non-shareholders) as the beneficiaries, CRA stated:
Critical illness insurance is generally equivalent to sickness or accident insurance. Even though critical illness insurance is under an individual insurance policy, this does not automatically mean that the insurance policy is not part of a group plan. It is our view that a group insurance plan refers to a plan under which a number of employees are insured either under a single policy between the insurer and an employer or under individual policies that are purchased as part of the plan set up by the employer for the group of insured employees.