30 November 1996 Ruling 9715563 - XXXXXXXXXX - SUPPLEMENTARY

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

RULINGS DIRECTORATE

CORRESPONDENCE SUMMARY

Principal Issues:

Minor changes to paragraphs 6 & 7 of the "Proposed Transactions" and the addition of wording to Ruling A for the purpose of clarifying the specific taxation year in which the reinsurance premium is to be deducted from and included in income.

Position TAKEN:

Changes agreed.

Reasons FOR POSITION TAKEN:

Minor change in facts and clarification. Not significant.

XXXXXXXXXX							971556
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1997

Dear Sir:

Re: Supplementary Advance Income Tax Ruling Request
XXXXXXXXXX

This is further to your telephone conversation of XXXXXXXXXX in regards to various amendments you have requested with respect to our advance income tax ruling (file 971298) issued XXXXXXXXXX, 1997 (the "Ruling"). The requested changes are as follows:

(1)The third sentence of paragraph 6 of the Ruling that reads, in part, "All such claims relate to amounts that will become due after the Closing Date..." is replaced with the following:

"All such claims relate to amounts that will be paid after the Closing Date...".

(2)The reference to "...an independent actuarial valuation..." in the first sentence of paragraph 7 of the Ruling is revised to delete reference to the word "independent".

(3)Ruling A is deleted and the following is substituted therefor:

A. The Reinsurance Premium paid or payable by XXXXXXXXXX in respect of the assumption by XXXXXXXXXX of the XXXXXXXXXX described in paragraph 4 above will, to the extent that it is reasonable, be an amount incurred by XXXXXXXXXX and received by XXXXXXXXXX in the course of carrying on their accident and sickness insurance businesses and as such will be deductible by XXXXXXXXXX and included in income by XXXXXXXXXX pursuant to section 9 in the taxation year the reinsurance premium is paid or payable.

We confirm that the above changes will not otherwise affect the rulings given in the Ruling and they will continue to be binding on the Department as indicated therein.

Yours truly,

for Director
Financial Industries Division
Income Tax Rulings and
Interpretations Directorate
Policy & Legislation Branch