Opco, as the revocable beneficiary of a life insurance policy, might be required to include an amount in income under subsection 246(1) of the Income Tax Act where the holdco-shareholders of Opco had paid the premiums under the policy. The CRA referred to technical interpretations 2009-0347291C6, 2009-0329911C6, and 2010-0359421C6 as “still valid”.
Question 2 2022 CTF Conference Roundtable summarized in Tax Topics no 2658 (February 14, 2023)
