Document ID: chunk:federal_register_of_legislation:C2025C00014:section:371:p3
Version: federal_register_of_legislation:C2025C00014
Segment Type: section
Provision Reference: s 371 (pt 3/3)
Character Range: 1968021–1968899

company on the actual disposal of the asset that accrued before the residence change time will be subject to tax in the listed country;
the taxpayer may elect to defer the timing of so much of the paragraph (1)(b) attribution credit as is attributable to the eligible part from the time of the change of residence referred to in that paragraph until immediately before the payment by the company of a dividend out of the gain derived by the company on the actual disposal of the asset.
 (9) An election for the purposes of subsection (8):
 (b) is irrevocable; and
 (c) has no effect unless it is made:
 (i) within 6 months after the end of the later of the following years of income:
 (A) the year of income in which the residence change time took place;
 (B) the year of income in which this subsection commenced; or
 (ii) within such further period as the Commissioner allows.