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          Income Tax

          Exempt Income of Business Trust and Unit Holders - Section 10(23FC), 10(23FCA), 10(23FD)

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          Exempt income of business trusts: distributed income and specified interest or rent exempt for unit holders; direct receipts taxable. Certain receipts of a business trust are tax-exempt: interest from a special purpose vehicle and specified dividends are exempt in the trust; REITs' income from renting or leasing real estate owned directly is exempt. Distributed income received by unit holders is exempt except where the distribution corresponds to the trust's exempt interest or the REIT's direct rental income, in which case the unit holder is taxable. Definitions and qualification conditions for business trust, special purpose vehicle and real estate asset align with the relevant securities regulations.
                        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.

                              Exempt income of business trusts: distributed income and specified interest or rent exempt for unit holders; direct receipts taxable.

                              Certain receipts of a business trust are tax-exempt: interest from a special purpose vehicle and specified dividends are exempt in the trust; REITs' income from renting or leasing real estate owned directly is exempt. Distributed income received by unit holders is exempt except where the distribution corresponds to the trust's exempt interest or the REIT's direct rental income, in which case the unit holder is taxable. Definitions and qualification conditions for business trust, special purpose vehicle and real estate asset align with the relevant securities regulations.


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