Commentary

E1.453C Life insurance gains—assignments involving co-ownership

Personal and employment tax

E1.453C Life insurance gains—assignments involving co-ownership

E1.453C Life insurance gains—assignments involving co-ownership

There may be a partial assignment of part of the rights under a policy or contract if, as a result of a transaction1:

  1.  

    •     all or part of the rights become beneficially owned by one or more persons, 'the new ownership'

  2.  

    •     before the transaction those rights (or part of those rights) were beneficially owned by one or more persons, 'the old ownership'

  3.  

    •     at least one person was a member of both the old and new ownership

  4.  

    •     if there was only one member of the old ownership, there are at least two

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