Income Tax Assessment Act 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-95 - VALUE SHIFTING  

Division 727 - Indirect value shifting affecting interests in companies and trusts, and arising from non-arm ' s length dealings  

Subdivision 727-G - The realisation time method  

Operative provisions

SECTION 727-615   727-615   Reduction of loss on realisation event for affected interest in losing entity  


If this Subdivision applies to a * realisation event that happens to an * affected interest in the * losing entity, a loss that would, apart from this Division, be * realised for income tax purposes by the event is reduced by an amount that is reasonable having regard to:


(a) a reasonable estimate of the amount (if any) by which the * indirect value shift has reduced the interest ' s *market value; and


(b) if the interest is also an affected interest in the * gaining entity - a reasonable estimate of the extent (if any) to which the interest ' s market value at the time of the realisation event still reflects the effect of the indirect value shift on the market value of * equity or loan interests in the gaining entity.


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