The North West Life Assurance Company of Canada - Page 4

                                                - 4 -                                                  

            Washington.  In addition, petitioner is licensed to transact                               
            business as a life insurance company in 20 other States.                                   
                  Petitioner's U.S. branch uses a calendar year accounting                             
            period and the accrual method of accounting.  Petitioner timely                            
            filed its Federal income tax returns (Forms 1120L) for tax years                           
            1988, 1989, and 1990.                                                                      
                  B.    Petitioner's Product Mix                                                       
                  Petitioner's U.S. branch operates primarily in the "section                          
            403(b) market", selling individual deferred annuities to school                            
            teachers.  Petitioner has the following product mix, measured by                           
            its reserves, during the years at issue:                                                   

                                          United States                                                
                  Individual Annuities          Individual Life Policies                               
                  1988        97.00%                              3.00%                                
                  1990        95.60                               4.40                                 
                                          Canada                                                       
                  Individual Annuities          Individual Life Policies                               
                  1988        64.73%                        35.27%                                     
                  1990        68.44                         31.56                                      
            Petitioner’s U.S. branch sold these products in the United                                 
            States, and petitioner's principal office in Vancouver sold them                           
            in Canada.                                                                                 
                  C.    Pricing of Products                                                            
                  Each of petitioner's annuity contracts includes an                                   
            accumulation period and a payout period.  During the accumulation                          






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011