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  • Additional modifications to the Act


    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

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    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 18000