In the context of a tax-deferred transfer of an insurance business carried on in Canada under s. 138(11.94), how are the terms “reinsurance premium” and “reinsurance commission” in s. 138(11.5)(m) interpreted? After noting that the rules applicable to the transfer of a discontinued business under s. 138(11.94) are set out in ss. 138(11.5)(e) to (m), and 138(11.7) to (11.9), CRA responded: