C. Keys (613) 593-6937
August 10, 1983
Dear Sirs:
We are writing in response to your letter of July 14, 1983 wherein you referred to a specific life insurance policy and requested our confir- mation that;
(a) the policy will continue to qualify as a pre-June 29, 1982 life insurance policy subsequent to its automatic renewal every fifth year, and
(b) a policy issued, as a replacement for the above-noted policy would be considered to be a new policy as opposed to a continuation of the existing one.
It is our view that the automatic renewal of the life insurance policy will not result in its disposition and therefore said policy will con- tinue to be "a life insurance policy of which the corporation was a beneficiary on or before June 28, 1982". As regards a replacement policy we would consider it to constitute a new life insurance policy for the purposes of paragraph 89(1)(b) of the Act.
Yours truly,
for Director Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch