Partner-firm distribution attribution (s. 72(5))

Revaluation cases (sub-rule 2). Where the amount taxed under section 67(10) (the excess of money and fair market value of assets received by the specified person over the capital account balance) relates to revaluation of a capital asset, or valuation of a self-generated asset or self-generated goodwill, the amount attributable to the capital asset remaining with the entity is A = B × (C / D), where B is the amount charged under section 67(10), C is the increase in or recognition of the value of the asset remaining with the entity because of revaluation or valuation, and D is the aggregate such increase or recognition for all assets.

No attribution (sub-rules 3 and 4). Where the amount charged does not relate to revaluation or valuation, it is not attributed to any capital asset for section 72(5). Irrespective of sub-rules (2) and (3), where the excess relates only to the capital asset received by the specified person from the entity, it is likewise not attributed.

Reporting (sub-rules 5 to 7). The specified entity furnishes details of the amount attributed in Form No. 27, verified by the person authorised to verify the entity's return under section 265, on or before the section 263(1)(c) due date for the tax year in which the amount is chargeable under section 67(10).

Further points (sub-rule 8). The amount relates to revaluation or valuation if the revaluation is based on a valuation report from a registered valuer (as defined in rule 56(f)). The specified entity gets no depreciation on the increase in value from revaluation, or on the recognition of the value of a self-generated asset or goodwill. "Self-generated asset" and "self-generated goodwill" have the meanings in section 67(11)(b).