Section EX 20 — Income Tax Act 2007: Reduction in attributed CFC loss

EX 20 Reduction in attributed CFC loss Application of this section: no economic loss (1) This section applies when— (a) a person has an amount of attributed CFC loss; and (b) the person suffers no, or substantially no, corresponding economic loss, whether because of a call option, a put option, or any other reason. Application of this section: attributed CFC loss excessive (2) This section also applies if— (a) a person has an amount of attributed CFC loss; and (b) the amount is more than any corresponding economic loss of the person, whether because of the application of the rules for calculating the person’s income interest or for any other reason. Reduction to economic loss (3) The attributed CFC loss is reduced to be equal to the economic loss, if any. Defined in this Act: amount , attributed CFC loss , income interest , Compare: 2004 No 35 s EX 20