Part 4Savings and investment income

Chapter 8Profits from deeply discounted securities

Disposals

438Timing of transfers and acquisitions

1

This section applies if—

a

a transfer or acquisition of a deeply discounted security is made under an agreement, and

b

the transferee or the person making the acquisition becomes entitled to the security at the time the agreement is made.

2

The transfer or acquisition is treated as occurring at that time.

3

For this purpose a conditional agreement is taken to be made when the condition is met.

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This section is subject to—

  • section 445(7) (exchanges for and consolidations of strips);

  • section 452F(4) (conversion into and consolidations of corporate strips).