Deemed crediting of accrued investment income: uncredited venture capital returns treated as credited to investors at year-end, preventing double taxation. Section 115U is amended to treat income 'accruing or arising to or received' by venture capital companies/funds as within the provision; obligations of the person crediting or making payments are aligned to the person liable to tax; references to 'paid' are replaced by 'paid or credited.' A new subsection deems accrued but unpaid or uncredited investment income as credited to investors on the last day of the previous year in their entitled proportion, and an Explanation provides that income taxed on accrual will not be taxed again when actually paid.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Deemed crediting of accrued investment income: uncredited venture capital returns treated as credited to investors at year-end, preventing double taxation.
Section 115U is amended to treat income "accruing or arising to or received" by venture capital companies/funds as within the provision; obligations of the person crediting or making payments are aligned to the person liable to tax; references to "paid" are replaced by "paid or credited." A new subsection deems accrued but unpaid or uncredited investment income as credited to investors on the last day of the previous year in their entitled proportion, and an Explanation provides that income taxed on accrual will not be taxed again when actually paid.
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