Attribution of tax on transferred capital assets: income chargeable to the transferor is attributed when received by a specified recipient. The amendment attributes to the value received by a specified person from a specified entity the portion of income that is chargeable to tax as the specified entity's income under the transfer provision, limited to the amount attributable to the capital asset being transferred and calculated in the prescribed manner.
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Provisions expressly mentioned in the judgment/order text.
Attribution of tax on transferred capital assets: income chargeable to the transferor is attributed when received by a specified recipient.
The amendment attributes to the value received by a specified person from a specified entity the portion of income that is chargeable to tax as the specified entity's income under the transfer provision, limited to the amount attributable to the capital asset being transferred and calculated in the prescribed manner.
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