Section 214 Taxable distribution method election

an election under section 213 is not in effect in relation to the owner,

the owner is not itself an investment entity, and

the owner can reasonably be expected to be subject to tax (in the territory in which it is located) on distributions from the entity at a rate equal to or exceeding 15%.

distributions and deemed distributions from the investment entity to the owner in an accounting period are to be included in the adjusted profits of the owner in that period;

credit the owner receives to reduce the tax payable by the owner in an accounting period to reflect tax payable or to be paid by the entity in that period is to be included in the adjusted profits of the owner in that period;

if the owner receives such credit, such tax payable or to be paid by the entity in an accounting period is to be taken into account in determining the covered tax balance of the owner in that period.

an undistributed income amount for the entity for an accounting period is to be determined under section 215, and

any positive undistributed income amount is to be added to the top-up amount of that entity as determined under section 220(1) (see section 220(2)).

an election under this section has been revoked, and

the adjusted profits of the investment entity fall to be determined under section 220 for the first accounting period in respect of which the election no longer applies.