Tax on income of foreign institutional investors imposes category-specific rates on securities income and capital gains, limiting deductions. The section establishes a rate-based tax regime for Foreign Institutional Investors and specified funds on income from securities and capital gains, requiring aggregate tax computation by income categories; limits application for specified funds to income attributable to non-resident unit holders or to specified investment divisions of offshore banking units; restricts certain deductions where income consists solely of securities income; and excludes section 72(6) for computing capital gains on the listed securities, with key terms defined for application.
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Provisions expressly mentioned in the judgment/order text.
Tax on income of foreign institutional investors imposes category-specific rates on securities income and capital gains, limiting deductions.
The section establishes a rate-based tax regime for Foreign Institutional Investors and specified funds on income from securities and capital gains, requiring aggregate tax computation by income categories; limits application for specified funds to income attributable to non-resident unit holders or to specified investment divisions of offshore banking units; restricts certain deductions where income consists solely of securities income; and excludes section 72(6) for computing capital gains on the listed securities, with key terms defined for application.
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