825. An insurer carrying on an insurance business in Canada and elsewhere in a taxation year must include in computing its income for the year from carrying on its insurance businesses in Canada the aggregate of(a) its gross investment revenue for the year from its designated insurance property for the year; and
(b) the amount prescribed in respect of the insurer for the year.
For the purposes of this section, gross investment revenue of an insurer for a taxation year is the amount by which the aggregate of the following amounts exceeds the aggregate of all amounts each of which is an amount deemed by paragraph b of section 125.0.1 to be paid by it in respect of the year as interest, or an amount deductible under paragraph b of section 851.22.4 in computing its income for the year:(a) any amount included in its gross revenue for the year, that is a taxable dividend or an amount received or receivable as, on account of, in lieu of or in satisfaction of, interest, rentals or royalties, other than an amount in respect of a debt obligation to which section 851.22.4 applies for the year;
(b) its income for the year from each trust of which it is a beneficiary or from each partnership of which it is a member;
(c) all amounts required by section 120 to be included in computing its income for the year;
(d) any amount required under paragraph a of section 851.22.4 to be included in computing its income for the year or, except to the extent that such amount has been included in computing its gross investment revenue by virtue of subparagraph a, under section 92 or 167; and
(e) the amount by which the aggregate of all amounts included by reason of paragraph c of section 312 in computing its income for the year exceeds the aggregate of all amounts deducted under paragraph f of section 336 in computing its income for the year.