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Highlights
CORPORATE-OWNED INSURANCE
Update on Changes to Dividend Taxation – Coming to
"GRIPs" With the Draft Legislation
Florence Marino
In the last issue of this journal,
Florence Marino reviewed the federal government's proposals to reduce the rate
of tax on certain types of dividend income received by individual taxpayers and
the implications of these measures on owners of Canadian-controlled private
corporations. In this article, Florence Marino reviews the more detailed draft
legislation introduced on June 29, 2006 that implements the dividend tax
proposals. The author then reviews the potential impact of these proposals on
buy-sell agreements funded with corporate-owned life insurance.
CHARITABLE GIVING
Charitable Giving, Qualifying Securities and Life
Insurance
Philip Friedlan, Kevin Wark
The May 2006 federal Budget contains
proposals that will make it even more attractive for taxpayers to donate
qualifying securities to certain charities by reducing the capital gains
inclusion rate on such donations to nil. In this article, Philip Friedlan
outlines the relevant tax provisions that apply to a gift of qualifying
securities by a corporate donor and uses a case study to quantify such benefits.
Kevin Wark then discusses the additional benefits that can arise where a
corporate donor acquires life insurance to preserve the value of the donated
capital and potential future growth.
TAX AND ESTATE PLANNING
The Canada Revenue Agency Responds: Tax Policy Roundtable
CALU 2006
Ted Ballantyne
At the CALU Annual Meeting on May 9,
2006, the Canada Revenue Agency ("CRA") was asked to respond to various
questions relating to tax and estate planning matters. Ted Ballantyne provides
an outline of selective questions that were posed to the CRA at the CALU
meeting. The author then provides a summary of the CRA's response to those
questions as well as applicable comments from CALU on the CRA
responses.
PRACTICE NOTES
Valuing a Charitable Gift of Insurance
Kevin Wark
Kevin Wark reviews a recent Canada
Revenue Agency ("CRA") Technical Interpretation that comments on the factors
that should be considered by a charity when valuing a life insurance policy that
had been the subject of a charitable donation. The author then discusses this
interpretation in light of specific provisions in the Income Tax Act as well as
other pronouncements from the CRA on the subject of valuing an insurance
policy.
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Board
Kevin Wark
Editor-in-Chief
PPI Financial Group
John Askin
The Wealth Strategy Group
Ted Ballantyne
Conference for Advanced Life Underwriting
Joel T. Cuperfain
Manulife Financial
Philip Friedlan
Friedlan Law Office
Greg Kaiser
London Life and Great-West Life
Florence Marino
Manulife Financial
Wayne G. Miller
Sun Life of Canada
Glenn R. Stephens
PPI Financial Group |