Regulation 2405

Subsection 2405(3)

Canadian Reserve Liabilities


Munich Reinsurance Co. v. The Queen, 96 DTC 6185, [1996] 2 CTC 5 (FCTD)

In calculating the Canadian reserve liabilities of the taxpayer (which was a German reinsurer carrying on business through a branch in Canada), the Minister was required to take into account a deduction with respect to deferred policy acquisition expenses, as required by s. 62(1)(b) of the Foreign Insurance Companies Act.

See Also

Victory Reinsurance Co. Ltd. v. MNR, 92 DTC 1869 (TCC)

The taxpayer, which was a U.K. company carrying on a reinsurance business through a branch in Canada, was required to include reserves for reinsurance ceded by it to unregistered non-resident reinsurers in its Canadian reserve liabilities.