47.1.1. For the purposes of section 47.1, an amount received by a person out of or under an employee benefit plan is deemed to have been received by another person (in this section referred to as the “individual”) and not by the person if(a) the person does not deal at arm’s length with the individual;
(b) the amount is received in respect of an office or employment of the individual; and
(c) the individual is living at the time the amount is received by the person.