Income Tax Regulations — 2400
iv) and (v) of the Act, as at the end of the year, and (C) the total of (I) the amount of the insurer’s attributed surplus for the year, and (II) if the amount under subclause (I) was determined without the taxpayer electing under subparagraph (b)(i) of the definition attributed surplus , the amount determined under subclause (A)(II). ( fonds de placement canadien ) Canadian investment property of an insurer for a taxation year means an investment property of the insurer for the year (other than, if the insurer is non-resident, property established by the insurer as not being effectively connected with its insurance businesses carried on in Canada in the year) that is, at any time in the year, (a) real property situated in Canada; (b) depreciable property situated in Canada or leased to a person resident in Canada for use inside and outside of Canada; (c) a mortgage, a hypothec, an agreement of sale or any other form of indebtedness in respect of property described in paragraph (a) or (b); (d) a Canadian equity property; (e) a Canadian resource property; (f) a deposit balance of the insurer that is in Canadian currency; (g) a bond, debenture or other form of indebtedness, in Canadian currency, issued by (i) a person resident in Canada or a Canadian partnership, or (ii) the government of Canada, a province or any of their political subdivisions; (h) a property that is (i) a share of the capital stock of a corporation resident in Canada that is affiliated with the insurer, if at least 75% of the total value for the year of all property of the corporation is attributable to property that would be Canadian investment property if it were owned by an insurer, or (ii) an interest in a Canadian partnership, or a trust resident in Canada, if at least 75% of the total value for the year of all property of the partnership or trust, as the case may be, is attributable to property that would be Canadian investment property if it were owned by an insurer; or (i) an amount due or an amount accrued to the insurer on account of income that (i) is from designated insurance property for the year that is Canadian investment property of the insurer for the year because of any of paragraphs (a) to (h), and (ii) is supporting the insurer’s Canadian insurance contract liabilities for the year. ( bien de placement canadien ) Canadian outstanding premiums [Repealed, 2022, c. 19, s. 85] Canadian reserve liabilities of an insurer as at the end of a taxation year means the amount determined by the formula A − A.1 + A.2 + A.3 − (0.9 × B) − (C − (0.9 × D)) where A is the total of the insurer’s liabilities and reserves including liabilities for segregated fund guarantees (other than policyholders’ liabilities or a liability for an obligation to pay a benefit under a segregated fund policy in respect of which subparagraphs 1406(b)(i) and (ii) apply) reported as at the end of the year in respect of (a) life insurance policies in Canada, (b) fire insurance policies issued or effected in respect of property situated in Canada, and (c) insurance policies of any other class covering risks ordinarily within Canada at the time the policy was issued or effected; A.1 is the total of all amounts each of which is the amount of an item reported by the insurer as an insurance contract asset as at the end of the year in respect of insurance policies described in any of paragraphs (a) to (c) of the description of A; A.2 is the total of all amounts each of which is an amount of funds withheld as at the end of the year by the insurer in respect of the reinsurance of a risk under an insurance policy described in any of paragraphs (a) to (c) of the description of A; A.3 is the total of all amounts each which is an amount recoverable as at the end of the year by the insurer under a funds withheld arrangement in respect of the reinsurance of a risk by the insurer under an insurance policy described in any of paragraphs (a) to (c) of the description of A; B is the total of all amo