Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p105
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 262591–265338

of the Constituent Entities of the MNE Group that are located in the jurisdiction for the earlier Fiscal Year; and
 (b) recalculate the Effective Tax Rate and Jurisdictional Top‑up Tax for the earlier Fiscal Year of the MNE Group for the jurisdiction in accordance with section 5‑95; and
 (c) despite paragraph 5‑95(3)(b), treat as Additional Current Top‑up Tax of the MNE Group for the jurisdiction for the departure year the amount that is:
 (i) any increase in Jurisdictional Top‑up Tax for the earlier Fiscal Year as a result of paragraph (b) of this subsection;
  multiplied by:
 (ii) the Disposition Recapture Ratio mentioned in subsection (3) for the Constituent Entity; and
 (d) reduce the balance of the Deemed Distribution Tax Recapture Account for the earlier Fiscal Year to zero.
 (3) The Disposition Recapture Ratio for the Constituent Entity is computed in according with the following formula:
where:
GloBE Income of the CE is the sum of the GloBE Income of the Constituent Entity for each Fiscal Year corresponding to the Deemed Distribution Tax Recapture Accounts for the jurisdiction.
Net Income of the jurisdiction is the sum of the Net GloBE Income of the MNE Group for the jurisdiction for each Fiscal Year corresponding to the Deemed Distribution Tax Recapture Accounts for the jurisdiction.

Part 7‑4—Effective Tax Rate computation for Investment Entities

Division 1—Application

7‑80  Application of this Part
 (1) This Part applies if one or more Constituent Entities of an MNE Group for a Fiscal Year are Investment Entities.
 (2) This Part does not apply in relation to an Investment Entity for a Fiscal Year to the extent it is a Tax Transparent Entity for the Fiscal Year.

7‑85  Insurance Investment Entity treated as Investment Entity
  For the purposes of this Part, treat an Insurance Investment Entity as an Investment Entity.

7‑90  Computing GloBE Income or Loss of Investment Entity
  For the purposes of this Part, in computing the GloBE Income or Loss of an Investment Entity, disregard that GloBE Income or Loss to the extent that the Investment Entity's GloBE Income or Loss is attributable to interests that are subject to an election under Part 7‑5 or 7‑6.

Division 2—Allocable Share of Top‑up Tax of Investment Entity

7‑95  Allocable Share of Top‑up Tax of Investment Entity
 (1) Section 2‑10 does not apply for the purposes of computing a Parent Entity's Allocable Share of the Top‑up Tax of an Investment Entity for a Fiscal Year.
 (2) Instead, that Allocable Share is an amount equal to:
 (a) the Top‑up Tax of the Investment Entity for the Fiscal Year;
multiplied by:
 (b) the fraction that is:
 (i) the Inclusion Ratio of the Parent Entity for the Investment Entity for the Fiscal Year, computed