10 August 1983 Income Tax Severed Letter 5-5294 - [830810]

By services, 22 July, 2022
Official title
[830810]
Language
English
Document number
Citation name
5-5294
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657595
Extra import data
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"field_release_date_new": "1983-08-10 08:00:00",
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Main text

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