The essence of a PIP definition is to catch any transfers of a PIP interest within the meaning of a chargeable transaction, as a share of partnership interest in a PIP is ultimately a share of the chargeable interests held by the PIP. An acquisition of a PIP interest is therefore traceable as an acquisition of an interest in the real property held by the PIP. Without the PIP provisions, the PIP structure would have allowed a chargeable acquisition of a partnership interest that is underpinned by the underlying assets to have gone untaxed.

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