Section 138

Subsection 138(1) - Insurance corporations

Articles

Paul Vienneau, "New Profit Accounting for Insurers", Canadian Tax Highlights, Vol. 25, No. 10, October 2017, p. 10

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Fred F.J. Borgmann, Canadian Insurance Taxation, (Butterworths Canada, 1998).

Paragraph 138(1)(a)

Cases

Consolidated-Bathurst Ltd. v. The Queen, 85 DTC 5120, [1985] 1 CTC 142 (FCTD), aff'd on different grounds, 87 DTC 5001, [1987] 1 CTC 55 (FCA)

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Paragraph 138(1)(d)

Subsection 138(2) - Insurer’s income or loss

See Also

London Life Insurance Co. v. The Queen, 89 DTC 6001 (FCA)

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Administrative Policy

14 May 2015 CLHIA Roundtable, 2015-0573801C6 - Foreign affiliates - sale of property to taxpayer

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a.1) exclusion where sale to foreign branch of Cdn insurer 207

Subsection 138(3) - Deductions allowed in computing income

Paragraph 138(3)(a)

Cases

Lutheran Life Insurance Society of Canada v. The Queen, 91 DTC 5553 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(4) 136

Subsection 138(9) - Computation of income

Cases

London Life Insurance Co. v. The Queen, 87 DTC 5312, [1987] 2 CTC 90 (FCTD), aff'd 90 DTC 6001 (FCA)

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Articles

Pennal, "Canadian Taxation of Non-Resident Insurers", 1989 Canadian Tax Journal, July-August issue, p. 1035

Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 2400 0

Subsection 138(11.3) - Deemed disposition

Cases

SCDA (2005) Inc. v. Canada, 2017 FCA 177

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 147 - Subsection 147(3) a settlement offer without an element of current monetary compromise can be reasonable 160

See Also

Standard Life Assurance Company of Canada v. The Queen, 2015 DTC 1113 [at 687], 2015 TCC 97

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Window Dressing acts purporting to evidence a Bermuda business were window dressing 185
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs starting a business entails taking "serious and continuous steps" to implement the "essential elements" of the business's goals 371

Subsection 138(11.5)

Paragraph 138(11.5)(m)

Administrative Policy

15 November 2016 External T.I. 2015-0597921E5 - Subsection 138(11.94) election

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Subsection 138(12) - Definitions

Life Insurance Policy

See Also

Higgins v. The Queen, 2013 DTC 1163 [at 889], 2013 TCC 194 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 160.2 112

Administrative Policy

10 October 2014 APFF Roundtable Q. 7, 2014-0538281C6 F - 2014 APFF Roundtable, Q. 7 - Insured annuity

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IT-87R2 "Policyholders' Income from Life Insurance Policies".