1 June 1990 Income Tax Severed Letter AC59081 - Tax on Investment Income of Life Insurers

By services, 22 July, 2022
Official title
Tax on Investment Income of Life Insurers
Language
English
Document number
Citation name
AC59081
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657624
Extra import data
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"field_release_date_new": "1990-06-01 08:00:00",
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Main text

EXPLANATORY NOTES

Reference Number:  5-908
                   211.1 ITA
                             ISSUES

Whether a non resident life insurer which does not carry on business in Canada and is not subject to Part 1 may be subject to Part XII.3 Tax on Investment Income of Life Insurers.

POSITION

Whether or not intended, such an insurer may be subject to Part XII.3 if it has any of the components in the formula contained in subsection 211.1(3).

NOTE: This was conveyed to the taxpayer on a verbal basis only, with a suggestion to discuss filing requirements with Special Audits Division.

B.G. Dodd Financial Industries Division Rulings Directorate