Income Tax Assessment Act 1936
(a) one or more schemes or arrangements have the effect of reducing the attribution percentage of an attributable taxpayer in relation to a company that is a CFC, and are intended by the attributable taxpayer or an associate of the attributable taxpayer to have that effect;
(b) a company ceases to be a CFC in relation to a particular taxpayer. 460A(2) [Calculating amount]
Work out the amount (if any) included under this Division in the taxpayer's assessable income because of CGT event J1 (as it notionally happens to the company under Division
) as though the reduction or cessation had not happened.
CGT event J1 is about companies ceasing to be related after a roll-over.