Income Tax Regulations — 2411
as the case may be, determined in respect of the insurer for the year under subsection (4) in respect of foreign investment property owned by the insurer at any time in the year; G.1 is the positive or negative amount, as the case may be, determined in respect of the insurer for the year under subsection (4.1) in respect of foreign investment property disposed of by the insurer in the year or a preceding taxation year; H is the total value for the year of foreign investment property (other than any property described in paragraph (e) of the definition investment property in subsection 2400(1)) owned by the insurer at any time in the year; and J is the total value for the year of the insurer’s foreign investment property (other than any property described in paragraph (e) of the definition investment property in subsection 2400(1)) that is designated insurance property of the insurer for the year. (4) The positive or negative amount, as the case may be, determined under this subsection in respect of an insurer for a taxation year in respect of property shall be the amount determined by the formula A - B where A is the total of the following amounts determined in respect of the property for the year, or that would be determined in respect of the property for the year if the property were designated insurance property of the insurer in respect of an insurance business in Canada for each taxation year in which the property was held by the insurer: (a) the insurer’s gross investment revenue for the year (other than taxable dividends that were or would be deductible in computing the insurer’s taxable income for the year under section 112 or subsection 138(6) of the Act) derived from the property, (b) [Repealed, SOR/2009-222, s. 4] (c) all amounts that were or would be included in computing the insurer’s taxable capital gains for the year from the disposition of the property, (c.1) all amounts that were or would be included under paragraph 142.4(5)(e) of the Act in respect of the property in computing the insurer’s income for the year, (d) all amounts that were or would be included in computing the insurer’s income for the year as gains from the disposition of such of the property as is not capital property or a specified debt obligation (as defined in subsection 142.2(1) of the Act), (e) all amounts that were or would be included in computing the insurer’s income for the year under subsection 13(1) of the Act in respect of the property, (f) all amounts that were or would be included in computing the insurer’s income for the year under paragraph 12(1)(d), (d.1) or (i) of the Act in respect of the property, (g) all amounts that were or would be included in computing the insurer’s income for the year under subsection 59(3.2) or (3.3) of the Act in respect of the property, and (h) [Repealed, 2016, c. 12, s. 80] (i) all other amounts that were or would be included in computing the insurer’s income for the year in respect of the property otherwise than because of subsection 142.4(4) of the Act; and B is the total of the following amounts determined in respect of the property for the year, or that would be determined in respect of the property for the year if the property were designated insurance property of the insurer in respect of an insurance business in Canada for each taxation year in which the property was held by the insurer: (a) all amounts that were or would be included in computing the insurer’s allowable capital losses for the year from the disposition of the property, (a.1) all amounts that were or would be deductible under paragraph 142.4(5)(f) of the Act in respect of the property in computing the insurer’s income for the year, (b) all amounts that were or would be deductible in computing the insurer’s income for the year as losses from the disposition of such of the property as is not capital property or a specified debt obligation (as defined in subsection 142.2(1) of the Act), (c) [Repealed, SOR/2009-222, s. 4] (d) all a