Advanced Tax Policy

CALU Tax Roundtable 2010

At the CALU Annual Meeting on May 4, 2010, Mark Symes, Director of the Financial Sector and Exempt Entities Division of the Income Tax Rulings Directorate, Canada Revenue Agency (CRA), responded to various questions of current concern to CALU members. The CRA´s official responses to the questions are provided in this Report, along with our summary of Mark Symes´ verbal responses to three additional questions. For some questions, CALU has provided a note of clarification or comment concerning the CRA responses. CALU would like to thank Ted Ballantyne, CALU´s former Director, Advanced Tax Policy; and Jillian Welch, Partner, Wilson and Partners LLP, CALU´s Tax Advisor, for their participation in the Roundtable. All statutory references are to the Income Tax Act (Canada) unless otherwise specified

2009 APFF Tax Roundtable

In October of 2009, L'Association de planification fiscale et financiere, APFF, held their annual convention in Montreal. At that time, a Tax Roundtable, coordinated by Mme Jocelyne Gagnon, a member of APFF and of CALU, was held with representatives of the Canada Revenue Agency and the Department of Finance Canada responding to questions of importance to the taxation and advanced planning applications of life insurance and related financial products. The attached PDF file is the English translation of a portion of the original document french language document which is also posted to this site. CALU would also like to recognize the efforts of CALU member Me. Helene Marquis, who is a member of the APFF Board of Directors.

Paul McKay, CAE

CALU Tax Roundtable 2008

At the CALU Annual Meeting on April 29, 2008, Mickey Sarazin, Director of the Financial Sector and Exempt Entities Division of the Income Tax Rulings Directorate of the Canada Revenue Agency (CRA), responded to various questions and technical issues of current concern. Our summary of his answers to the general questions as well as the CRA´s official responses to the technical questions are provided in this Report. For some questions, CALU has provided a note of clarification or comment concerning the official responses. CALU would also like to thank Ted Ballantyne, CALU´s Director, Advanced Tax Policy and Jillian Welch, Partner, Wilson and Partners LLP, CALU´s Tax Advisor, for their participation in the Roundtable. All statutory references are to the Income Tax Act (Canada) unless otherwise specified.

2008 APFF Tax Roundtable

In October of 2008, L'Association de planification fiscale et financiere, APFF, held their annual convention in Quebec. At that time, a Tax Roundtable, coordinated by APFF and CALU member Jocelyne Gagnon, Director Taxation (Quebec) for PPI Financial Group, was held with representatives of the Canada Revenue Agency responding to questions of importance to the taxation and advanced planning applications of life insurance and related financial products. The attached PDF file is the English translation of the original document.

2007 APFF Tax Roundtable

In October of 2007, L'Association de planification fiscale et financiere, APFF, held their annual convention in Montreal. At that time, a Tax Roundtable, coordinated by APFF and CALU member Jocelyne Gagnon, Director Taxation (Quebec) for PPI Financial Group, was held with representatives of the Canada Revenue Agency and Department of Finance responding to questions of importance to the taxation and advanced planning applications of life insurance and related financial products. The attached pdf file is the English translation of the original document. I would also like to thank Me Helene Marquis, also a member of CALU and the APFF, for her time and expertise clarifying key aspects of the document, as we worked to complete this very extensive translation effort on behalf of the advanced life underwriting community in Canada.

CALU Tax Roundtable 2006

At the CALU Annual Meeting on May 9, 2006, Phil Jolie, Acting Director of the Business and Partnerships Division of the Income Tax Rulings Directorate of the Canada Revenue Agency (CRA), responded to various questions regarding technical issues of current concern. The following are the questions and the CRA´s position on the respective issues. For some questions, CALU has provided a note of clarification or comment concerning the official responses. All statutory references are to the Income Tax Act (Canada) unless otherwise specified.

CALU Tax Roundtable 2005

At the CALU Annual Meeting on May 3, 2005, Mickey Sarazin, Acting Director of the Financial Industries Division of the Income Tax Rulings Directorate of the Canada Revenue Agency (CRA), responded to various questions and technical issues of current concern. For some questions, CALU has provided a note of clarification or comment concerning the official responses. CALU also thanks Denis Normand, Senior Chief of the Financial Institutions Section of the Business Income Tax Division of the Tax Policy Branch of the Department of Finance and William R. Holmes, for their participation in the Roundtable. (Please note that all statutory references are to the Income Tax Act (Canada) unless otherwise specified.)

CALU Tax Roundtable 2004

At the CALU Annual Meeting on May 4, 2004, Mickey Sarazin, Acting Director of the Financial Industries Division of the Income Tax Rulings Directorate of the Canada Revenue Agency (CRA), responded to various questions and technical issues of current concern. The following are the questions and the Agency's position on such issues as transfer of a life insurance policy, gift of a life insurance policy to charity, corporate-owned life insurance, and borrowing to acquire common shares. For some questions, CALU has provided a note of clarification or comment concerning the official responses. All statutory references are to the Income Tax Act (Canada) unless otherwise specified.