Document ID: chunk:federal_register_of_legislation:C2025C00029:section:5:p3
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 5 (pt 3/5)
Character Range: 6686833–6689656

ultimate owner is one of 2 or more ultimate owners because of whom the conditions in an item in the table in section 727‑400 are satisfied, the ownership or rights of that kind in relation to the company or trust held by the associate at that time:
 (c) to the extent of a particular percentage, may be treated as being instead held by the other ultimate owner; and
 (d) to the extent so treated, cannot be treated as being instead held by any other ultimate owner of whom the first ultimate owner is an associate.
 (5) If one or more applications of subsection (4) are necessary to establish that an *ultimate owner is one of 2 or more ultimate owners because of whom the conditions in an item in the table in section 727‑400 are satisfied, that subsection must be applied accordingly.

Subdivision 727‑F—Consequences of an indirect value shift

Guide to Subdivision 727‑F

727‑450  What this Subdivision is about

      This Subdivision tells you:
         • which method to use to work out the consequences of an indirect value shift for equity or loan interests, and indirect equity or loan interests, in the losing entity and in the gaining entity; and
         • which interests, and which owners, are affected.

Table of sections

Operative provisions
727‑455 Consequences of the indirect value shift

Affected interests
727‑460 Affected interests in the losing entity
727‑465 Affected interests in the gaining entity
727‑470 Exceptions
727‑520 Equity or loan interest and related terms
727‑525 Indirect equity or loan interest

Affected owners
727‑530 Who are the affected owners

Choices about method to be used
727‑550 Choosing the adjustable value method
727‑555 Giving other affected owners information about the choice

Operative provisions

727‑455  Consequences of the indirect value shift
  The consequences (if any) of an *indirect value shift must be worked out using the *realisation time method unless the *adjustable value method is chosen in accordance with section 727‑550.
Note: Later provisions of this Subdivision set out the interests to which those consequences apply (see sections 727‑460 to 727‑525), which are in turn determined by who are the affected owners (see section 727‑530).

Affected interests

727‑460  Affected interests in the losing entity
  These are the affected interests in the *losing entity:
 (a) each *equity or loan interest that an *affected owner owns in the losing entity immediately before the *IVS time; and
 (b) each equity or loan interest that:
 (i) an affected owner owns in another affected owner immediately before the IVS time; and
 (ii) is an *indirect equity or loan interest in the losing entity;
(except one covered by an exception in section 727‑470).

727‑465  Affected interests in the gaining entity
  If immediately before the *IVS time the *gaining