Clubbing of income: income from revocable transfers is included in the transferor's total income for tax purposes. Income arising from a revocable transfer is to be included in the transferor's total income. A revocable transfer includes settlements, trusts, covenants, agreements or arrangements where the transferor retains revocability. The transferor is the taxable person for income produced by the asset, and the rule attributes tax liability to the transferor rather than the transferee for such revocable arrangements.