After quoting authorities on the meaning of "security," including a statement in Canadian & Foreign Securities Co. v. M.N.R., [1972] C.T.C. 391 at 395, 72 DTC 6354 at 6356 (F.C.T.D.) referring to "instruments for the payment of money," the questioner submitted that "segregated funds should be considered ‘securities' within the popular sense or commercial meaning of the term." CRA responded:
A segregated fund policy is a contract of insurance and … is not a share or security of the taxpayer. Consequently … paragraph 20(1)(bb) … does not apply to fees paid by a taxpayer in respect of the advisability of the acquisition or disposition of segregated fund policies, or for the administration or management thereof as the requirements of that paragraph are not met.