CRA noted that if a trust did not qualify as an employee life and health trust (ELHT) under s. 144.1(2) or if payments in connection therewith did not constitute employer contributions to an ELHT:
the premiums paid and contributions made would not generally be deductible by participating employers pursuant to subsection 144.1(4) of the Act but could be deductible as an expense incurred for the purpose of gaining or producing income from a business.