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        <h1>Section 311: Taxing AOP/BOI Income at Highest Marginal Rate When Members' Shares Are Indeterminate, With Higher Personal Rates Applied</h1> Section 311 prescribes taxing an AOP/BOI's total income at the maximum marginal rate when members' shares are indeterminate, except that if any member's personal tax rate exceeds that maximum, the higher rate applies; where shares are determinate, income portions attributable to higher-rate members are taxed at their rates and the balance at the maximum marginal rate. A deeming rule treats indeterminacy at formation or later as sufficient. The Bill and the Act are substantively aligned; differences are drafting and ordering, with the Bill slightly clearer in tying the exempt threshold to the Finance Act.

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