Jeff , age 55, immigrated to Canada from Scotland in his 20s. Over the years, he built a small chain of budget-rate hotels in the GTA and has become wealthy beyond his dreams. His private corporation, Nessie Inc., owns the hotels and, in some cases, the land on which the hotels are built. Two years ago Nessie purchased a $6,000,000 Manulife term insurance policy on Jeff’s life. Nessie is both the owner and beneficiary of this policy.