LLM6190 - Conversion: Schedule 20A FA93: Nameco conversions: trading losses
FA93/SCH20A/PARA2 applies where the converting Name receives income from the Nameco, and continues to own the majority of shares in, and to control, the company throughout a tax year. It allows trading losses from before the conversion to be set off against subsequent income derived from the company, under the 바카라 사이트ścarry forward provision바카라 사이트ť, which means ICTA88/S385 and ITA07/S83. On a claim, therefore, the income derived from the company is treated as if it were underwriting profits. As with trade transfer relief, ICTA88/S386 and ITA07/S86, such income can be remuneration, dividends or other income.