Corporate Insured Retirement Plan (CIRP)

The Corporate Insured Retirement Plan (CIRP) shows shareholders of Canadian-controlled private corporations (CCPCs) the benefits of protecting their corporation with permanent life insurance. It's also a financial strategy that provides additional tax-efficient retirement income.

This is how a CIRP works:

  • The policyowner, a Canadian-controlled private corporation, takes out a permanent life insurance policy with cash value.
  • The policyowner pays the premiums or deposits, which generates cash value over time.
  • After several years, when the shareholder decides to retire, the corporation that holds the policy or the insured person (the shareholder) borrows money in the form of a loan or line of credit from a financial institution and agrees to use the insurance policy as collateral.
    Important: This strategy may vary depending if the borrower is the corporation or the shareholder. Work with the client to determine which would be better for their situation.
  • In the projections for this strategy, no payments are made on the loan principal or capitalized interest during the insured person's lifetime.
  • Upon the death of the insured, the settlement process will depend on who borrowed the money:

    Corporation loan

    • The insurance amount is paid, tax-free, to the corporation.
    • The loan taken out with the financial institution, including interest, is paid back during the settlement of the insurance policy.
    • The excess insurance amount can be paid to the estate as a non-taxable dividend through the capital dividend account (this sum can't exceed the insurance amount minus the adjusted cost base (ACB) of the policy).
      If there's a surplus, it will be paid to the estate through the ordinary dividend account, which is taxable.

    Shareholder loan

    • Since the shareholder took out the loan for themselves with the financial institution, and since the corporation agreed to secure this personal loan with an asset belonging to them, it's important that the estate releases the insurance policy at the time of death by replacing it with assets belonging to the insured person or their estate as collateral.
    • Only under this condition will we pay the tax-free insurance amount to the corporation.
      Upon the death of the shareholder, there would be a taxable benefit if the death benefit (which the corporation is entitled to) is used to directly pay the shareholder's loan balance.
    • The sum of the insurance amount minus the ACB is paid to the estate through the dividend account without tax deductions. The difference, equivalent to the ACB, is paid to the estate through the ordinary dividend account, which is taxable.
    • The estate then pays off the loan and the surplus is paid out according to the wishes of the deceased.
      Important: If the shareholder took out the loan personally and the corporation agreed to use their asset as collateral (in this case, the insurance policy), they must pay their corporation annual guarantee fees or declare a taxable benefit that can take 1 of 2 forms:
      • The difference between the interest rates on the loan with and without the collateral (usually around 2%)
      • The fees that the shareholder would have to pay to an unrelated third party to obtain collateral on the loan as accepted by the corporation, usually a fixed annual percentage (around 1%) applicable to the increased value of the loan

    These options are included in the report, and it's your responsibility to understand and explain to your client the effects these fees can have on the net amounts received in the medium and long term. Your client can then decide which approach would be best for them, whether the corporation takes out the loan or they do.

    We've included a checklist you can use to confirm that your client has been informed in writing and understands that a taxable benefit must be included in their income. They'll also need to consult a tax specialist to determine the amount of the taxable benefit, which we are in no way responsible for.

    Ideally, a client should get confirmation from their tax specialist that they were advised on the amount of the taxable benefit prior to the implementation of this approach. The client is responsible for paying the tax specialist's fees.

Note: Determining the amount of the taxable benefit will depend on your client's specific situation (for example, their credit file and the collateral for the loan). The amount of the taxable benefit can also vary if their situation changes (for example, if their credit score drops).