A particular Ontario tax on life insurance corporations ("SAT") is determined as a fixed percentage of the amount by which the corporation's taxable paid-up capital exceeds the total of the corporation's Ontario corporate income tax and corporate minimum tax payable for the year. By virtue of being added to the corporation's corporate minimum tax credit carry forward, this tax may then be deducted to reduce future years' income taxes.
The SAT is a capital tax and not an income tax, notwithstanding its potential creditability against income taxes payable, and therefore the incurring of the tax leads to a corresponding deduction in computing income. "In the absence of a specific prohibition in the Income Tax Act to the contrary, provincial capital taxes have been considered to be expenditures incurred for the purpose of gaining or producing income from a business or property and therefore deductible in computing income for federal income tax purposes."