Capital asset cost treatment updated: conversions to LLPs deemed to carry over pre-conversion share acquisition cost for tax purposes. The amendment expands the cross-reference in the capital gains cost computation provision to include an additional transfer clause and adds a deeming rule that where partner rights become capital assets on conversion under the Limited Liability Partnership framework, the cost of acquisition of the asset is deemed to be the cost of the share or shares in the company immediately before conversion, thereby aligning conversions with other specified transfer categories for cost determination.
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Capital asset cost treatment updated: conversions to LLPs deemed to carry over pre-conversion share acquisition cost for tax purposes.
The amendment expands the cross-reference in the capital gains cost computation provision to include an additional transfer clause and adds a deeming rule that where partner rights become capital assets on conversion under the Limited Liability Partnership framework, the cost of acquisition of the asset is deemed to be the cost of the share or shares in the company immediately before conversion, thereby aligning conversions with other specified transfer categories for cost determination.
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