• What if a CFC fails the active income test?

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    If a CFC fails the active income test, amounts that would be assessable if the CFC were a resident are included in attributable income to the extent they represent the following:

    • eligible designated concession income that is adjusted tainted income
    • low-taxed third country income (only where it is of a kind specified in the Regulations)
    • trust amounts arising to the CFC directly that are not subject to tax in a listed country
    • trust amounts arising to the CFC indirectly because the CFC is a partner in a partnership, if the amounts are not subject to tax in a listed country, or
    • FIF income derived directly by the CFC or indirectly as a partner in a partnership.

    Any other amounts are notional exempt income.

    Last modified: 05 Dec 2006QC 18000