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        <h1>Section 210 imposes fixed tax rates and segregation rules for foreign institutional investors' securities income and capital gains</h1> Section 210 creates a special tax regime for foreign institutional investors and specified funds, requiring segregation of securities income and specified short- and long-term capital gains and taxing each category at fixed rates (e.g., 20%/10% for securities income, 30%/20% for certain short-term gains, 12.5% for long-term gains), with residual income taxed at general rates. Specified funds are taxed only on income attributable to units held by non-residents; attribution and certain procedural calculations are to be prescribed. Where gross income consists solely of securities income, many deductions are disallowed; section 72(6) is excluded for the listed capital gains. Textual differences between bill and statute mainly clarify drafting and cross-references.

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