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Federal Court of Appeal upholds Tax Court of Canada's decision on life insurer's tax reserves

Stikeman Elliott LLP
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Canada
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February 1 2008

On January 15, 2008, the Federal Court of Appeal upheld a decision by Justice Hershfield of the Tax Court of Canada, finding for the respondent, the National Life Assurance Company of Canada (National Life), in respect of policy reserves taken for its 1997 and 1998 taxation years

US insurers have no PE in Canada

Borden Ladner Gervais LLP
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Canada, USA
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June 19 2008

On May 16, 2008, the Tax Court of Canada released its judgments in American Income Life Insurance Company v. The Queen and Knights of Columbus v. The Queen

CDA before court

Miller Thomson LLP
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Canada
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June 8 2010

The Income Tax Act considers the income earned through a private corporation in the same framework as income earned directly by an individual

Alberta Court of Appeal upholds decision that extended warranties are not insurance for tax purposes

Cassels Brock & Blackwell LLP
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Canada
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July 28 2011

On July 21, 2011, the Court of Appeal of Alberta released its decision in Brick Protection Corporation v Alberta (Provincial Treasurer), 2011 ABCA 214 (“Brick Protection”

Commentary on October 24, 2012 Notice of Ways and Means Motion relating to tax matters - insurance corporations

Osler, Hoskin & Harcourt LLP
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Canada
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November 1 2012

Except with respect to one proposal in respect of policy reserves for segregated life insurance policies, most of the changes to section 138 of the Act and Part XIV of the Income Tax Regulations are clarifying changes or changes made to repeal obsolete provisions

Obligors of extended product warranties are not “insurance companies" in Alberta

Gowling Lafleur Henderson LLP
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Canada
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August 15 2011

On July 21, 2011, the Alberta Court of Appeal unanimously held that fees earned through the sale of extended warranties on furniture, appliances and electronic equipment were not subject to provincial tax

Revenue Minister can't use audit to "chill" business

Borden Ladner Gervais LLP
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Canada
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March 13 2013

In MNR v. RBC Life Insurance Company et al., 2013 FCA 50, the Federal Court of Appeal held that the Minister of National Revenue could not use her

Brick Protection Corp. v. Alberta (Treasury) are warranty providers subject to insurance corporation tax under Part IX of the Alberta Tax Act?

Dentons
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Canada
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September 21 2011

The Alberta Court of Appeal released its decision in this appeal on July 21, 2011

Information-gathering and tax audits by a revenue authority could there be an ulterior purpose?

DLA Cliffe Dekker Hofmeyr
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Canada
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May 10 2013

The Canadian Federal Court of Appeal's (FCA) recent judgment in MNR v RBC Life Insurance Co, 2013 FCA 50 (decided on 21 February 2013) condemned the

Life insurance policy reserves

Gowling Lafleur Henderson LLP
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Canada
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March 22 2011

Section 1406 of the Income Tax Regulations (“ITR”) sets out rules for calculating life insurance policy reserves under s. 1404 and 1405. Section 1406 is being amended in response to decisions of the Tax Court of Canada (“TCC”) and the Federal Court of Appeal (“FCA”) in National Life Assurance Co. v. R., 2006 TCC 551 (aff’d 2008 FCA 14) (“National Life Assurance”

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