Pass-through taxation of investment fund income: unit holders taxed as if investments were held directly, with specified loss rules. Income of a unit holder from investments made through an investment fund is taxed in the unit holder's hands as if the investment were made directly by them; income unpaid during the year is deemed credited on the last day of the tax year in proportion to entitlement, and income included on accrual is not taxed again on payment. Fund losses are subject to carve-outs: business losses remain with the fund and follow carry forward rules, certain non business losses are excluded from pass through if units were held under twelve months, and specified accumulated losses are deemed to belong to unit holders who held units on the relevant historical date.
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.
Pass-through taxation of investment fund income: unit holders taxed as if investments were held directly, with specified loss rules.
Income of a unit holder from investments made through an investment fund is taxed in the unit holder's hands as if the investment were made directly by them; income unpaid during the year is deemed credited on the last day of the tax year in proportion to entitlement, and income included on accrual is not taxed again on payment. Fund losses are subject to carve-outs: business losses remain with the fund and follow carry forward rules, certain non business losses are excluded from pass through if units were held under twelve months, and specified accumulated losses are deemed to belong to unit holders who held units on the relevant historical date.
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