Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p111
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 277534–280409

election does not apply because of the revocation.

Part 7‑6—Taxable distribution method election

7‑140  Application of this Part
  This Part applies in relation to an Insurance Investment Entity in the same way that it applies in relation to an Investment Entity.

7‑145  Taxable distribution method election
 (1) A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to:
 (a) a specified Constituent Entity of the MNE Group that is an Investment Entity; and
 (b) a specified Constituent Entity‑owner of the Investment Entity that:
 (i) is not an Investment Entity; and
 (ii) if the Constituent Entity‑owner holds an Indirect Ownership Interest in the Investment Entity—holds the Indirect Ownership Interest through a chain of Investment Entities.
 (2) An election under subsection (1) is a Five‑Year Election.

7‑150  Effect of election—distributions and deemed distributions received by Constituent Entity‑owner included in computing its GloBE Income, etc.
 (1) This section applies if an election under subsection 7‑145(1) applies to:
 (a) an Investment Entity that is a Constituent Entity of an MNE Group; and
 (b) a Constituent Entity‑owner of the Investment Entity; and
 (c) a Fiscal Year (the reporting year).
 (2) In computing the Constituent Entity‑owner's GloBE Income or Loss for the reporting year, include distributions and deemed distributions on which it is subject to Tax for the reporting year to the extent that they are attributable to the GloBE Income of the Investment Entity.
 (3) In computing the Constituent Entity‑owner's:
 (a) GloBE Income for the reporting year; and
 (b) Adjusted Covered Taxes for the reporting year;
include an amount equal to so much of the Investment Entity's Covered Taxes for the reporting year as is allowed, under local tax law, as a credit against the Constituent Entity‑owner's Tax liability for the reporting year arising in connection with a distribution from the Investment Entity.
 (4) In computing the MNE Group's Effective Tax Rate under Chapter 5 and Part 7‑4 for the Fiscal Year for the jurisdiction in which the Investment Entity is located, exclude:
 (a) the Investment Entity's GloBE Income or Loss for the Fiscal Year; and
 (b) the Investment Entity's Adjusted Covered Taxes for the Fiscal Year, to the extent that they are attributable to such income (except as provided in subsection (3)).

7‑155  Effect of election—where positive balance of Undistributed Net GloBE Income Account after 3 Fiscal Years, increase Top‑up Tax for tested year
 (1) This section applies if:
 (a) an election under subsection 7‑145(1) applies to:
 (i) an Investment Entity that is a Constituent Entity of an MNE Group; and
 (ii) a Constituent Entity‑owner of the Investment Entity; and
 (iii) a Fiscal Year (the tested year); and
 (b) there is an Undistributed