Related Commentary  

48(1)  This regulation applies if an offshore fund ceases to be a non-reporting fund and becomes a reporting fund.

48(2)  A participant in the fund may make an election to be treated–

(a)as disposing of the interest owned by the participant in the non-reporting fund at its market value on the disposal date, and

(b)as acquiring a holding in the reporting fund at the beginning of the reporting fund's first period of account.

This is subject to paragraphs (5) and (5A).

48(3)  Chapter 5 of this Part applies to determine the offshore income gain arising on the deemed disposal referred to in paragraph (2)(a).

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