Legal Opinion

North W. Life Assur. Co. of Can. v. Commissioner

United States Tax Court

Decided December 12, 1996No. Docket No. 4694-94Published

P, a Canadian insurance company, operated through a permanent establishment in the United States for purposes of the income tax convention between the United States and Canada. P reported its net investment income effectively connected with its conduct of an insurance business within the United States pursuant to sec. 842(a), I.R.C., without regard to the minimum amount of net investment income that sec. 842(b), I.R.C., treated as effectively connected.

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P, a Canadian insurance company, operated through a permanent establishment in the United States for purposes of the income tax convention between the United States and Canada. P reported its net investment income effectively connected with its conduct of an insurance business within the United States pursuant to sec. 842(a), I.R.C., without regard to the minimum amount of net investment income that sec. 842(b), I.R.C., treated as effectively connected. P claimed under the Convention With Respect to Taxes on Income and on Capital, Sept. 26, 1980, U.S.-Can., T.I.A.S. No. 11087, 1986-2 C.B. 258…

1Opinion of the Court

THE NORTH WEST LIFE ASSURANCE COMPANY OF CANADA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

North W. Life Assur. Co. of Can. v. Commissioner

Docket No. 4694-94.

United States Tax Court

107 T.C. 363; 1996 U.S. Tax Ct. LEXIS 50; 107 T.C. No. 19;

December 12, 1996, Filed

Decision will be entered for petitioner.

P, a Canadian insurance company, operated through a permanent establishment in the United States for purposes of the income tax convention between the United States and Canada. P reported its net investment income effectively connected with its conduct of an insurance business…

Also in this document: Concurrence; Dissent.

2Cases cited22 opinions

  1. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
  2. Reid v. CovertSupreme Court of the United States · 1957
  3. Bogardus v. CommissionerSupreme Court of the United States · 1937
  4. Sumitomo Shoji America, Inc. v. AvaglianoSupreme Court of the United States · 1982
  5. United States v. RauscherSupreme Court of the United States · 1886

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