Commentary

B5.710 Conversion of non-reporting fund

Business tax
Business tax | Commentary

B5.710 Conversion of non-reporting fund

Business tax | Commentary

B5.710 Conversion of non-reporting fund

If an offshore fund ceases to be a non-reporting fund and becomes a reporting fund (see B5.715), a participant in the fund may elect to be treated as disposing of an interest in the non-reporting fund at its market value on the disposal date and as acquiring an interest in a reporting fund1. An election cannot be made unless the gain on the disposal is greater than zero2. The election must be included in the participant's tax return for the tax year (for income tax purposes) or the accounting period (for corporation tax purposes) which

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