A New Tax System (Australian Business Number) 1999 2 - Registering for ABN Purposes 5 - Your obligations if you are registered Division 5 - Your obligations if you are registered Part 2 - Registering for ABN Purposes to the A New Tax System (Australian Business Number) Act 1999 INCOME TAX ASSESSMENT 1997 Paragraph 2 - LIABILITY RULES OF GENERAL APPLICATION Section 36-10 How to calculate a tax loss for an income year Subdivision 36-A - Deductions for tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS to the INCOME TAX ASSESSMENT Act 1997 Section 36-17 How to deduct tax losses of corporate tax entities Subdivision 36-A - Deductions for tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-A - Deducting tax losses of earlier income years & 165-E - The same business test 165-12 Company must maintain the same owners & 165-13 Alternatively, the company must satisfy the same business test & 165-210 The test Section 165-12 Company must maintain the same owners & 165-13 Alternatively, the company must satisfy the same business test & 165-210 The test Subdivision 165-A - Deducting tax losses of earlier income years & 165-E - The same business test Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS to the INCOME TAX ASSESSMENT Act 1997 Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 Subdivision 770-A - Transitional foreign losses (common rules) Division 770 - Foreign income tax offsets and foreign losses Part 4-5 - GENERAL Chapter 4 - INTERNATIONAL ASPECTS OF INCOME TAX to the INCOME TAX (TRANSITIONAL PROVISIONS) Act 1997 INCOME TAX ASSESSMENT 1997 2 - LIABILITY RULES OF GENERAL APPLICATION 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS 36 - Tax losses of earlier income years 36-A - Deductions for tax losses of earlier income years Subdivision 36-A - Deductions for tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-A - Deducting tax losses of earlier income years & 165-E - The same business test 165-12 Company must maintain the same owners & 165-13 Alternatively, the company must satisfy the same business test & 165-210 The test Section 165-12 Company must maintain the same owners & 165-13 Alternatively, the company must satisfy the same business test & 165-210 The test Subdivision 165-A - Deducting tax losses of earlier income years & 165-E - The same business test Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-A - Deducting tax losses of earlier income years 165-10 To deduct a tax loss Section 165-10 To deduct a tax loss Subdivision 165-A - Deducting tax losses of earlier income years Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-B - Working out the taxable income and tax loss for the income year of the change & 165-CB - Working out the net capital gain and the net capital loss for the income year of the change Subdivision 165-B - Working out the taxable income and tax loss for the income year of the change & 165-CB - Working out the net capital gain and the net capital loss for the income year of the change Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-CC - Change of ownership or control of company that has an unrealised net loss 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Section 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Subdivision 165-CC - Change of ownership or control of company that has an unrealised net loss Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-CC - Change of ownership or control of company that has an unrealised net loss 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Section 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Subdivision 165-CC - Change of ownership or control of company that has an unrealised net loss Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-CC - Change of ownership or control of company that has an unrealised net loss 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Section 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Subdivision 165-CC - Change of ownership or control of company that has an unrealised net loss Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-CC - Change of ownership or control of company that has an unrealised net loss 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Section 165-115C Changeover time - change in ownership of company & 165-115D Changeover time - change in control of company Subdivision 165-CC - Change of ownership or control of company that has an unrealised net loss Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-35 - INSURANCE BUSINESS 320 - Life insurance companies 320-D - Income tax, taxable income and tax loss of life insurance companies 320-141 Tax loss - complying superannuation/FHSA class Section 320-141 Tax loss - complying superannuation/FHSA class Subdivision 320-D - Income tax, taxable income and tax loss of life insurance companies Division 320 - Life insurance companies Part 3-35 - INSURANCE BUSINESS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-30 - SUPERANNUATION 295 - Taxation of superannuation entities 295-B - Modifications of provisions of this Act Subdivision 295-B - Modifications of provisions of this Act Division 295 - Taxation of superannuation entities Part 3-30 - SUPERANNUATION Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 complying superannuation/FHSA Section 995-1 Definitions Division 995 - Definitions Part 6-5 - DICTIONARY DEFINITIONS Chapter 6 - THE DICTIONARY to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1936 X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES 1 - Preliminary 317 INTERPRETATION Section 317 INTERPRETATION Division 1 - Preliminary Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 340 CONTROLLED FOREIGN COMPANY (CFC) Subdivision B - Controlled foreign entities (CFEs) Division 2 - Types of entity Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Sections 456 ASSESSABILITY IN RESPECT OF CFC'S ATTRIBUTABLE INCOME, 456A REDUCTION OF SECTION 456 ASSESSABILITY WHERE ITEM SUBJECT TO FOREIGN ACCRUALS TAX, 457 ASSESSABILITY WHERE CFC CHANGES RESIDENCE FROM UNLISTED COUNTRY TO LISTED COUNTRY OR TO AUSTRALIA, 458 ASSESSABILITY IN RESPECT OF CERTAIN DIVIDENDS PAID BY A CFC & 459 ASSESSABILITY IN RESPECT OF CERTAIN DIVIDENDS DEEMED TO BE PAID BY A CFC UNDER SECTION 47A Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 INCOME TAX ASSESSMENT 1936 X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES 1 - Preliminary 317 INTERPRETATION Section 317 INTERPRETATION Division 1 - Preliminary Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 340 CONTROLLED FOREIGN COMPANY (CFC) Subdivision B - Controlled foreign entities (CFEs) Division 2 - Types of entity Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Sections 456 ASSESSABILITY IN RESPECT OF CFC'S ATTRIBUTABLE INCOME, 456A REDUCTION OF SECTION 456 ASSESSABILITY WHERE ITEM SUBJECT TO FOREIGN ACCRUALS TAX, 457 ASSESSABILITY WHERE CFC CHANGES RESIDENCE FROM UNLISTED COUNTRY TO LISTED COUNTRY OR TO AUSTRALIA, 458 ASSESSABILITY IN RESPECT OF CERTAIN DIVIDENDS PAID BY A CFC & 459 ASSESSABILITY IN RESPECT OF CERTAIN DIVIDENDS DEEMED TO BE PAID BY A CFC UNDER SECTION 47A Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 INCOME TAX ASSESSMENT 1997 2 - LIABILITY RULES OF GENERAL APPLICATION 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS 36 - Tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 Division 245 - Forgiveness of commercial debts Schedule 2C-FORGIVENESS OF COMMERCIAL DEBTS to the INCOME TAX ASSESSMENT Act 1936 Section 707-415 Application of losses with nil available fraction for certain purposes Subdivision 707-D - Special rules about losses Division 707 - Losses for head companies when entities become members etc. Part 3-90 - CONSOLIDATED GROUPS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 Section 36-10 How to calculate a tax loss for an income year Subdivision 36-A - Deductions for tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 Section 26-55 Limit on deductions Division 26 - Some amounts you cannot deduct, or cannot deduct in full Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT ACT 1997 2 - LIABILITY RULES OF GENERAL APPLICATION 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS 36 - Tax losses of earlier income years 36-C - Excess franking offsets Subdivision 36-C - Excess franking offsets Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT ACT Act 1997 Section 6-20 Exempt income Division 6 - Assessable income and exempt income Part 1-3 - CORE PROVISIONS Chapter 1 - INTRODUCTION AND CORE PROVISIONS to the INCOME TAX ASSESSMENT Act 1997 Section 36-17 How to deduct tax losses of corporate tax entities Subsection 36-17(3), 36-17(4) & 36-17(5) Subdivision 36-A - Deductions for tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 Section 36-20 Net exempt income Subdivision 36-A - Deductions for tax losses of earlier income years Division 36 - Tax losses of earlier income years Part 2-5 - RULES ABOUT DEDUCTIBILITY OF PARTICULAR KINDS OF AMOUNTS Chapter 2 - LIABILITY RULES OF GENERAL APPLICATION to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT ACT 1997 CHAPTER 3 - SPECIALIST LIABILITY RULES PART 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Division 170 - Treatment of certain company groups for income tax purposes Subdivision 170-A - Transfer of tax losses within certain wholly-owned groups of companies Subdivision 170-A - Transfer of tax losses within certain wholly-owned groups of companies Division 170 - Treatment of certain company groups for income tax purposes Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT ACT Act 1997 INCOME TAX ASSESSMENT 1997 3 - SPECIALIST LIABILITY RULES 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS 165 - Income tax consequences of changing ownership or control of a company 165-A - Deducting tax losses of earlier income years & 165-E - The same business test 165-12 Company must maintain the same owners & 165-13 Alternatively, the company must satisfy the same business test & 165-210 The test Section 165-12 Company must maintain the same owners & 165-13 Alternatively, the company must satisfy the same business test & 165-210 The test Subdivision 165-A - Deducting tax losses of earlier income years & 165-E - The same business test Division 165 - Income tax consequences of changing ownership or control of a company Part 3-5 - CORPORATE TAXPAYERS AND CORPORATE DISTRIBUTIONS Chapter 3 - SPECIALIST LIABILITY RULES to the INCOME TAX ASSESSMENT Act 1997 INCOME TAX ASSESSMENT 1997 3-1 - CAPITAL GAINS AND LOSSES: GENERAL TOPICS 102 - Assessable income includes net capital gain 102-10 How to work out your net capital loss & 102-15 How to apply net capital losses Section 102-10 How to work out your net capital loss & 102-15 How to apply net capital losses Division 102 - Assessable income includes net capital gain Part 3-1 - CAPITAL GAINS AND LOSSES: GENERAL TOPICS to the INCOME TAX ASSESSMENT Act 1997 Spreading the Benefits of the Boom Legislation Amendment (Loss Carry-back) Bill 2012 Spreading the Benefits of the Boom Legislation Amendment (Loss Carry-back) Bill 2012 has not yet been passed by Parliament. It proposes a variation to Division 160 of the Income Tax Assessment Act 1997. Section 340 Subdivision B - Controlled foreign entities (CFEs) Division 2 - Types of entity Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 425 SOMETIMES-EXEMPT INCOME ETC. Subdivision D - Modifications relating to losses View history reference Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 426 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 427 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 428 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 429 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 430 Subdivision D - Modifications relating to losses Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 431 Division 7 - Calculation of attributable income of CFC Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 456 ASSESSABILITY IN RESPECT OF CFC'S ATTRIBUTABLE INCOME Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 456A REDUCTION OF SECTION 456 ASSESSABILITY WHERE ITEM SUBJECT TO FOREIGN ACCRUALS TAX Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 457 ASSESSABILITY WHERE CFC CHANGES RESIDENCE FROM UNLISTED COUNTRY TO LISTED COUNTRY OR TO AUSTRALIA Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 458 Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 459 ASSESSABILITY IN RESPECT OF CERTAIN DIVIDENDS DEEMED TO BE PAID BY A CFC UNDER SECTION 47A Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Section 459A ASSESSABILITY WHERE CFC OR CFT HAS INTEREST IN CERTAIN ATTRIBUTABLE TAXPAYERS Division 9 - Attribution of attributable income and other amounts Part X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES to the INCOME TAX ASSESSMENT Act 1936 Subdivision 770-C - Transitional foreign losses (special rules for CFCs) Division 770 - Foreign income tax offsets and foreign losses Part 4-5 - GENERAL to the INCOME TAX (TRANSITIONAL PROVISIONS) Act 1997 Former subsection 424(1) 0f the 1936 Act