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Topic: Book Reports
Number of pages / Number of words: 13 / 3400
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The net income is further reduced by other amounts, which included amount, which is already taxed under another provision or comparably taxed by a listed country which may argue that its application is to avoid double taxation or way reconciliation with other provision in the Act.

In brief, HK trust is in an unlisted foreign trust that has not received any dividends from HK Co...


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It is arguable that for this reason, no income was ever received or accumulated in HK trust to be attributable. Hence, this criterion is not satisfied and the transferor trust rules may not be applicable.

2. Deemed Present Entitlement Rules

The operative provisions in the deemed present entitlement rules are set out in sections 96A to 96C of the ITAA 1936, as an extension of the normal operations of section 97 so that it applies to tax resident beneficiaries on their portion or “interest” in the net income of a foreign trust estate...


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