Proportionate attribution of trust income treats beneficiaries' receipts as derived from taxable and non taxable portions accordingly. When only part of a trust's income is chargeable to tax, a beneficiary's receipt is deemed to be derived proportionately from the chargeable and non chargeable portions, the chargeable proportion equalling the ratio of the chargeable part to the whole trust income for purposes of determining taxable income.
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Provisions expressly mentioned in the judgment/order text.
Proportionate attribution of trust income treats beneficiaries' receipts as derived from taxable and non taxable portions accordingly.
When only part of a trust's income is chargeable to tax, a beneficiary's receipt is deemed to be derived proportionately from the chargeable and non chargeable portions, the chargeable proportion equalling the ratio of the chargeable part to the whole trust income for purposes of determining taxable income.
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