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of <h1>Income remains taxable to the transferor when income is transferred but the underlying asset is not, regardless of revocability</h1> Where income is transferred by any person, whether the transfer is revocable or irrevocable and whether made before or after the Act's commencement, but the asset generating that income is not transferred, the income remains taxable as the transferor's income and must be included in the transferor's total income for income-tax purposes.
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