Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p113
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 282714–285453

are Investment Entities;
 (c) if the Investment Entity has a GloBE Loss for the Fiscal Year—the GloBE Loss;
 (d) if the Investment Entity has a GloBE Loss for a previous Fiscal Year covered by subsection (3)—the GloBE Loss, to the extent that it has not been applied under a previous operation of paragraph (c) or this paragraph.
 (6) For the purposes of subsection (5):
 (a) apply an amount mentioned in paragraph (5)(a) before applying an amount mentioned in paragraph (5)(b); and
 (b) apply an amount mentioned in paragraph (5)(b) before applying an amount mentioned in paragraph (5)(c); and
 (c) apply an amount mentioned in paragraph (5)(c) before applying an amount mentioned in paragraph (5)(d).
 (7) For the purposes of paragraph (5)(d), apply a GloBE Loss for an earlier Fiscal Year before applying a GloBE Loss for a later Fiscal Year.

7‑165  Deemed distributions
 (1) This section applies if:
 (a) an Investment Entity is a Constituent Entity of an MNE Group; and
 (b) there is an Undistributed Net GloBE Income Account for the Investment Entity for a Fiscal Year; and
  (c) the balance of the Undistributed Net GloBE Income Account is above zero at the end of the Fiscal Year; and
 (d) a Constituent Entity‑owner of the Investment Entity has a proportionate share of the Undistributed Net GloBE Income Account at a time in the Fiscal Year; and
 (e) an Ownership Interest of the Constituent Entity‑owner in the Investment Entity is transferred at that time to an Entity that is not a Group Entity of the MNE Group.
 (2) For the purposes of this Part:
 (a) treat the Investment Entity as having made a deemed distribution to the Constituent Entity‑owner at that time; and
 (b) treat the amount of the deemed distribution as being the amount of the proportionate share at that time (disregarding this section).

7‑170  Effect of revoking election
 (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
 (b) the election is revoked in a Fiscal Year (the revocation year); and
 (c) there is an Undistributed Net GloBE Income Account for the Investment Entity for the Fiscal Year that is the second Fiscal Year preceding the revocation year; and
  (d) the balance of the Undistributed Net GloBE Income Account is above zero at the end of the revocation year.
 (2) In computing the Investment Entity's GloBE Income or Loss for the revocation year, include the Constituent Entity‑owner's proportionate share of the balance of the Undistributed Net GloBE Income Account (the Constituent Entity‑owner's undistributed share).
 (3) For purposes of Chapter 2:
 (a) treat