Regarding the availability of the s. 6(1)(f) exclusion regarding payments received pursuant to individual long-term care policies (without a return of premium rider at maturity) that had been provided to senior executives (non-shareholders) by their employer, CRA stated:
Periodic payments received by employees under such long-term care insurance are not taxable by virtue of paragraph 6(1)(f) if they are received as a result of the fulfillment of certain conditions stipulated in the insurance contract as compensation for care received at home or in an institution and not for the loss of income from an office or employment.
Regarding pay-outs under critical illness insurance, CRA stated:
Where the executive employee receives the lump sum payment for this insurance, we are of the view that this amount is not taxable by virtue of paragraph 6(1)(f) since, inter alia, this type of insurance does not provide the beneficiary with income in the form of periodic payments.