The appellants, holding companies owned by a majority shareholder, appealed reassessments adding taxable benefits to their income for the 2014-2017 taxation years.
The benefits related to life insurance premiums paid by an operating company, R3D, on policies owned by the appellants.
The Tax Court of Canada dismissed the appeals, finding that the payment of premiums by R3D constituted a taxable benefit to the appellants under subsections 15(1) and 246(1) of the Income Tax Act, as the appellants were enriched by not having to pay the premiums themselves.
