The taxpayers were shareholders and directors of a corporation, which they caused to purchase insurance policies on their lives. The agent who arranged the policies then returned a substantial portion of the premiums directly to the taxpayers in cash. Favreau J. upheld the Minister's decision to reassess beyond the normal period and impose penalties under s. 163(2). The taxpayer's contention that the amounts were a gift was not credible, given the amount of the gifts and their regularity (the taxpayers had done the same thing before). The court also drew an adverse inference from the taxpayers' decision not to have the insurance agent testify.
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directors' life insurance not a gift from corporation
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
334848
Extra import data
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