V.A. Sider (613) 993-6937
March 25, 1985
Dear XXXX
Re: Paragraph 148(10)(e) and 89(1)(b)
In response to your letter of March 1, 1985 it is our opinion that paragraph 146(10)(e) does not apply for the purposes of paragraphs 89(1)(b) and (b.2). In other words, where a life insurance policy last acquired before December 2, 1982 has been acquired by a corporation after December 1, 1982 fron a person with whom it was not dealing at arm's length, the corporation would not be considered to be a beneficiary of that life insurance policy on June 28, 1982 for the purposes of paragraph 89(1)(b) or (b.2).
Yours truly,
for Director Bilingual Services & Finance Division Corporate Rulings Directorate Legislation Branch