851.22.22.11. The rules set out in the second paragraph apply to a taxpayer for a particular taxation year of the taxpayer where(a) the taxpayer holds a transition property in the particular taxation year;
(b) the property was a mark-to-market property of the taxpayer for the taxation year preceding the particular taxation year; and
(c) the property is not a mark-to-market property of the taxpayer for the particular taxation year.
The rules to which the first paragraph refers are as follows:(a) the taxpayer is deemed to have ceased to be an insurer at the particular time that is the beginning of the particular taxation year; and
(b) the taxation year ending immediately before the taxpayer’s particular taxation year is deemed to end at the time that is immediately before the particular time.