Florence Marino is Vice President, Tax & Estate Planning at Tompkins Insurance in Toronto. Prior to joining, Florence was the Head of Tax, Retirement & Estate Planning at Manulife. In her new role at Tompkins, Florence will continue her active involvement in the tax and estate planning community and be a resource to professionals in the field for their valued clients.

In recent years, corporate-owned life insurance has become an important planning tool in meeting the estate planning objectives and goals of business owners. Often in a family business setting, corporate-owned life insurance is purchased to fund tax liabilities arising on the death of a business owner, to facilitate business succession objectives and to enable estate equalization goals. Life insurance shares are yet another tool which may be used in serving these objectives.

Florence will discuss the general attributes and characteristics of these shares, the main situations where they may be used, what is accomplished by the use of them; and the tax and non-tax issues associated with their use. The main question relating to life insurance shares is one of valuation at the time of issue, and one of the main tax risks in structuring life insurance shares is the potential shifting of value through inadequate consideration being paid for the shares, and/or corporate impoverishment resulting in benefit conferral.