Featured Articles
Is My IFA Tax Shelter (Statutory Review)
Application of subsection 237.1(1), section 143.2, and Regulation 3100 to IFA structures
Oct. 13, 2026
This memorandum provides a comprehensive framework for analyzing whether an Immediate Financing Arrangement (IFA) qualifies as a tax shelter under the Income Tax Act (ITA). It systematically exami...
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Is My IFA a Tax Shelter? (in Plain English)
A simplified, plain-English version of our statutory analysis regarding the exposure of Immediate Financing Arrangements to tax shelter status.
Oct. 1, 2026
This memorandum offers a simplified, plain-English version of our comprehensive statutory technical analysis regarding the exposure of Immediate Financing Arrangements (IFAs) to tax shelter status...
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The Not-So-Sweet Honey Trap: What the Court’s Ruling Means for IFAs
If you are a professional advising on, structuring, or participating in financed insurance strategies, the mechanics of how the CRA won this case serve as a direct blueprint for possible similar enforcement against IFAs.
Sept. 17, 2026
The Tax Court of Canada recently released its decision in Honey v. The King (2026 TCC 170) . While the case formally addresses the disallowance of interest deductions on legacy 10/8 life insuran...
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