Law360 Canada ( November 6, 2026, 9:36 AM EST) -- Appeal by the Minister of National Revenue (Minister) from a judgment of the Tax Court concerning the Independent Order of Foresters (Order). The Income Tax Act (Act) exempted the Order from paying tax on its income, but the exemption did not apply to its taxable income from its life insurance business. This taxable income had to be computed on the assumption that the Order had no income or loss from any other sources. The appeal was about whether that assumption allowed the Order to blend its life insurance and accident and sickness insurance (accident insurance) businesses when computing its taxable life insurance income. The Order included its accident insurance assets and liabilities in computing its Canadian investment fund, designated the $199,462,344 excess to its accident insurance business and excluded its World Surplus assets. The Tax Court disagreed with the Minister. It found that the World Surplus assets were non-insurance assets....