Rishabh Jain is a member of Institute of Chartered Accountants of India (ICAI) since 2015 and graduate in commerce in the year 2013 from University of Delhi. His core area of expertise is advisory, compliances and litigation of direct tax, international tax and transfer pricing. He has considerable experience in advising large corporate houses and high net worth individuals on a variety of tax matters including domestic and international issues. In his previous assignments, Rishabh has experience with top mid size firm specializing in income tax and transfer pricing compliances, advisory and litigation activities. He also represents clients in tax and transfer pricing litigation matters before various appellate forums. Rishabh discourse at various professional forums and regularly contributes articles to variety of journals and professional practice manuals. Mobile: +91-9990564434 Email: [email protected]
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Dividend stripping: statutory rules can ignore capital losses near record dates, with uncertainty after dividend taxation reform.
The article explains statutory anti-avoidance rules that ignore capital losses arising from acquisitions and disposals around a record date where dividends or bonus allotments are involved: dividend stripping rules disallow losses to the extent of exempt dividend when acquisition and disposal fall within prescribed pre- and post-record date periods; bonus stripping rules ignore losses on original units and deem such ignored loss as the cost of allotted bonus units when prescribed conditions are cumulatively met. It also discusses the Budget 2020 change making dividends taxable and the resulting uncertainty over application of the dividend-stripping restriction. (AI Summary)
Income Tax