Additional modifications to the Act



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End of attention

Three additional modifications are made in working out the net income of a partnership.

  • First, the partnership is treated as a resident of the same country as the CFC.
  • Secondly, a dividend will not be notional exempt income of a partnership unless the dividend is paid out of previously attributed income.
  • Thirdly, the capital gains tax provisions apply to assets acquired by a partnership after 19 September 1985 - the deemed acquisition of assets on 30 June 1990 for CFCs does not apply to assets held by partnerships.
Last modified: 05 Dec 2006QC 17522