17 February 2016 External T.I. 2015-0608261E5 - Splitting of a Multiple Life Insurance Policy -- summary under Disposition

Respecting the exercise by a policyholder of a contractual right to split a universal life insurance policy covering two lives into two policies, CRA indicated that whether there was a disposition on general principles (before looking at s. 148(10)(d)) turned on whether “the changes that are made to the terms of the policy…are so fundamental as to go to the root of the policy.”