Words and Phrases - "main purpose"
4 August 1999 External T.I. 9908235 F - PARAGRAPHE 112(3.2) - REGLE TRANSITOIRE
correspondence with insurance company could demonstrate main purpose of policy
Did correspondence between the insurance company and the beneficiary of the life insurance policy specifying that the policy was taken out to fund the repurchase of frozen shares constitute sufficient documentary evidence for the purposes of s. (b)(iii) of the effective-date provision for s. 112(3.2)? The Directorate responded that the letter exchanged between the insurance company and the corporation could constitute conclusive documentary evidence to show that, as of April 26, 1995, it was reasonable to conclude that one of the main purposes of the policy was to fund, directly or indirectly, in whole or in part, the repurchase of the corporation's shares.
Words and Phrases
main purpose