G.D. Middleton (613) 995-0051 XXXX
July 14, 1986
We are writing in reply to your letter of April 23, 1986 concerning the income tax treatment for long term disability group insurance plans. We apologize for the delay in our reply.
We understand that the premiums for your current group insurance plan are fully paid by XXXX any long term disability benefits received by employees are taxable, presumably under paragraph 6(1)(f) of the Income Tax Act.
You describe an alternative arrangement in which group insurance plan premiums are added to each employee's income as a taxable benefit. We assume that you are referring to an arrangement that is an "Employee Pay-All Plan", as described in paragraphs 16 to 21 of Interpretation Bulletin IT-428 (copy enclosed). In this type of plan, the entire premium cost is paid by the employees and any disability benefits received out of this plan are not taxable.
As indicated in paragraph 18 of IT-428 , if an employer pays group insurance premiums for some employees, but not all, and the other employees pay their own premiums, the plan will not be considered to be an Employee Pay-All Plan even for those other employees. Therefore, if certain employees request the Employee Pay-All Plan income tax treatment, you may, as suggested, consider the establishment of separate plans to accommodate their wishes.
We trust our comments are of assistance to you.
Yours truly,
For Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch