The North West Life Assurance Company of Canada v. Commissioner

107 T.C. No. 19

UNITED STATES TAX COURT THE NORTH WEST LIFE ASSURANCE COMPANY OF CANADA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4694-94. Filed December 12, 1996. 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.…