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The notional assessable income of a CFC in a broad-exemption listed country includes amounts derived from sources outside the CFC's country of residence if the amounts are not taxed in a listed country. This rule does not apply to amounts of eligible designated concession income-these amounts may be included if the CFC fails the active income test.
Amounts of adjusted tainted income derived from sources outside a CFC's country of residence will also be included if they have not been taxed in a broad-exemption listed country. The source of an amount is to be determined according to the laws of the CFC's country of residence.
Last modified: 05 Dec 2006QC 17522