Section 4 - Quarantining of losses
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Where a CFC's notional allowable deductions relating to a particular class are more than the notional assessable income of that class for an accounting period, the excess cannot be claimed against notional assessable income of another class or used to reduce a net capital gain under the capital gains tax provisions.
The excess loss of a class of income is carried forward and can be claimed as a notional allowable deduction against income of the same class.
What are the classes of income?
Notional assessable income is divided into four classes:
- offshore banking
- modified passive
- other income.
The classes may include both income and gains of a capital nature. However, capital gains under the capital gains tax provisions are not included in any of the classes. In effect, these capital gains are treated as a separate class of income.
Most interest income, including payments in the nature of interest, falls into the interest class.
- interest that falls into the offshore banking income class
- interest that is received in the active conduct of a trade or business - for example, interest on receivables
- interest derived from money lending - for example, a banking business.
Offshore banking income
Offshore banking income is income derived through an offshore banking unit. It is unlikely that a CFC will have this type of income.
Modified passive income
Modified passive income is passive income other than amounts that fall within the interest class or the offshore banking income class. As mentioned previously, capital gains under the capital gains tax provisions are not included. Passive income includes rent, royalties, dividends, annuities, capital gains and amounts derived from the assignment of, for example, copyrights.
Last modified: 05 Dec 2006QC 17522