Does the concept of "advantage" in s. 207.01(1) apply to a split-dollar arrangement where the RCA holds the cash surrender value of the insurance contract and another person or entity holds the death benefit, with the holder of the death benefit adequately financing the mortality costs? CRA responded:
[I]t is possible that the concept of advantage as defined in subsection 207.5(1) would apply in certain circumstances to the situation presented. However … given that the terms and conditions of these types of contracts may vary significantly, we are unable to comment on the application of the concept of advantage to co-ownership agreements or split-premium life insurance arrangements.