Income Tax Regulations — 2400
ies as at the end of the year is of (ii) the insurer’s weighted total liabilities as at the end of the year; (b) in respect of a non-resident insurer (other than a life insurer), 25% of the total of (i) the insurer’s mean Canadian reserve liabilities for the year, and (ii) the insurer’s property and casualty surplus for the year; and (c) in respect of a non-resident life insurer, the total of (i) either, (A) if the insurer makes an election referred to in subparagraph (b)(i) of the definition attributed surplus for the year, the greater of (I) that proportion of the total of all amounts each of which is the value for the year of an equity property of the insurer that 1 the insurer’s weighted Canadian liabilities as at the end of the year is of 2 the insurer’s weighted total liabilities as at the end of year, and (II) 8% of the insurer’s mean Canadian investment fund for the year, or (B) if the insurer does not make this election for the year, 8% of the insurer’s mean Canadian investment fund for the year, (ii) 25% of the insurer’s mean Canadian reserve liabilities for the year, and (iii) 25% of the insurer’s property and casualty surplus for the year. ( plafond des avoirs ) equity property of a person or partnership (in this definition referred to as the “taxpayer”) at any time means property of the taxpayer that is (a) a share of the capital stock of, or an income bond or income debenture, issued by, another person (other than a corporation affiliated with the taxpayer) or partnership; or (b) that proportion of property that is shares of the capital stock of a corporation affiliated with the taxpayer or an interest in a partnership or trust that (i) the total value for the taxation year or fiscal period of the corporation, partnership or trust that includes that time of equity property of the corporation, partnership or trust, as the case may be, is of (ii) the total value for the year or period of all property of the corporation, partnership or trust, as the case may be. ( avoir ) financial institution means a corporation that is (a) a corporation described in any of paragraphs (a) to (e) of the definition restricted financial institution in subsection 248(1) of the Act; or (b) a particular corporation all or substantially all of the value of the assets of which is attributable to shares or indebtedness of one or more corporations described in paragraph (a) to which the particular corporation is affiliated. ( institution financière ) foreign policy loan [Repealed, 2022, c. 19, s. 85] gross Canadian life investment income of a life insurer for a taxation year means the amount, if any, by which (a) the total of all amounts each of which is (i) the insurer’s gross investment revenue for the year, to the extent that the revenue is from Canadian business property of the insurer for the year in respect of the insurer’s life insurance business, (ii) the amount included in computing the insurer’s income for the year under paragraph 138(9)(b) of the Act, (iii) the portion of the amount deducted under paragraph 20(1)(l) of the Act in computing the insurer’s income for its preceding taxation year that was in respect of Canadian business property of the insurer for that year in respect of the insurer’s life insurance business, (iv) the amount included under section 142.4 of the Act in computing the insurer’s income for the year in respect of property disposed of by the insurer that was, in the taxation year of disposition, Canadian business property of the insurer for that year in respect of the insurer’s life insurance business, (v) the insurer’s gain for the year from the disposition of a Canadian business property of the insurer for the year in respect of the insurer’s life insurance business, other than a capital property or a property in respect of the disposition of which section 142.4 of the Act applies, or (vi) the insurer’s taxable capital gain for the year from the disposition of a Canadian business property of the insurer for