Full text
where tax would have been payable had the property been purchased in Canada from the person at the time it was transferred, the insurer is deemed to have made, at the particular time, a taxable supply of the property and to have collected, at the particular time, all tax payable in respect of that supply, which is deemed to be equal to the amount determined by the formula(A/B) × C where A is if the property is situated in a participating province at the particular time, the total of the rate set out in subsection 165(1) and the tax rate for that province, and in any other case, the rate set out in subsection 165(1), B is the total of 100% and the percentage determined for A, and C is the fair market value of the property at the time it was transferred.