A partnership held, was the beneficiary of and paid the premiums for 10 years on, three policies on the lives of each of the three individuals who were its partners and then, pursuant to the partnership agreement, transferred the applicable policy to one of the partners (Individual C) on that member’s withdrawal from the partnership. Two years later, Individual C gifted the policy to a registered charity. CRA stated:
[T]he period during which the partnership held the life insurance policy is not included in the determination of the period during which Individual C was the policyholder of the life insurance policy for the purposes of subsection 248(35).