The appellant, a fraternal benefit society and life insurer, appealed an assessment for its 2014 taxation year regarding the taxation of investment income.
The Minister reassessed the appellant to include World Surplus assets in its Canadian Investment Fund (CIF) and to exclude amounts in respect of its Accident and Sickness (A&S) Business.
The Tax Court allowed the appeal, finding that the appellant correctly included A&S Business assets and liabilities in computing its CIF, correctly designated investment property in respect of its A&S Business, and correctly excluded certain World Surplus assets that were not used or held in the course of carrying on an insurance business.
