Revocable transfer defined as arrangements permitting the transferor to regain economic benefit or control, affecting income attribution.

Definitions establish that transfer includes settlements, trusts, covenants, agreements or arrangements. A revocable transfer exists where the instrument permits direct or indirect re-transfer of income or assets to the transferor, or where the transferor can directly or indirectly re-assume power over any part of the income or assets, thereby qualifying such transfers for income-attribution under the relevant provisions.

---

---

---