910509
(613) 957-8953
24(1)19(1)March 19, 1991
Dear Sirs:
This is in reply to your letter dated February 14, 1991 with respect to the income tax treatment of securities transactions entered into by insurance corporations.
It is a question of fact as to whether the gain or loss with respect to any particular securities transaction entered into by an insurance corporation in the course of its business is on income or capital account. We can confirm that it is our view that as securities transactions are an integral part of the business carried on by an insurance corporation such gains or losses will generally be on income account.
It would be inappropriate for us to speculate as to the views held or position taken in this regard by the insurance industry or related associations, such as the 24(1)
We hope this is of some assistance.
Yours truly,
Chief Financial Institutions Section Financial Industries Division Rulings Directorate
000193