Question juridique clé
Whether interest on loans connected to single-premium life insurance is deductible for tax purposes.
Solution extraite
The deduction may be refused where the financing constitutes tax avoidance; the court confirmed the 2/3 net-wealth limit as a relevant benchmark.
Motifs extraits
Under the applicable tax rules, debt interest is generally deductible, but not when the financing structure is unusual and chosen primarily to save tax. The court reaffirmed that single-premium insurance financed by debt can amount to tax avoidance if the debt exceeds two-thirds of net assets valued at market value, without latent real-estate gains tax.