The definition of reporting entity in s. 233.3 references its “cost amount” of specified foreign property. Is the cost amount of an interest in a life insurance policy the adjusted cost basis ("ACB”) as defined in s. 148(9), or the premiums paid? After noting that para. (f) of the s. 248(1) “cost amount” definition referenced the cost to the taxpayer of the property as determined for the purpose of computing the taxpayer’s income, CRA stated:
[T]he "adjusted cost basis" of a holder's interest in a life insurance policy, as defined in subsection 148(9), can generally be considered a reasonable estimate of the cost of the property for the purposes of the application of the rules of section 233.3.