AN OVERVIEW OF DOMESTICATION TRANSACTIONS IN THE INSURANCE INDUSTRY
Bibliographic record
Abstract
The transfer of an insurance business is subject to a variety of special rules contained in the Income Tax Act. Subsections 138(11.5) and (11.94) govern the tax-deferred transfer of an insurance business by a non-resident and a Canadian-resident insurer, respectively. Subsection 138(11.92), on the other hand, provides rules for the transfer of an insurance business on a fully taxable basis. This article will describe “domestication transactions” involving the transfer of an insurance business and will review the application of subsection 138(11.5) to such transactions. The article will also discuss some of the regulatory issues that arise in the context of domestication transactions. Finally, the article will provide an analysis and discussion of the various tax provisions and illustrate the post-transaction effects of a completed domestication transaction.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.001 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.005 | 0.008 |
| Science and technology studies | 0.002 | 0.001 |
| Scholarly communication | 0.005 | 0.007 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.002 | 0.002 |
| Insufficient payload (model declined to judge) | 0.006 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".