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Item 22 - Attributed foreign income

See item 22: Attributed foreign income on the ATO website.

For more information on the calculation of the amounts shown at labels M and X, see the ATO's Foreign income return form guide (NAT 1840).

Label S—Did you have overseas branch operations or a direct or indirect interest in a foreign trust, foreign company, controlled foreign entity or transferor trust?

Direct or indirect interests in a controlled foreign company or a foreign trust (CFCs) have the same meaning as set out in Division 3 of Part X of the ITAA 1936.

A partnership has an interest in a transferor trust if the partnership has ever made, or caused to be made, a transfer of property or services to a non-resident trust. See section 102AAB of the ITAA 1936 for the definition of the transfer of property and services.

If the answer to this question is yes, select Y at label S. Click label S to complete an International dealings schedule (ids) for the current income year.

If the answer is no, select N at label S and don't complete the IDS schedule.

If the partnership was a subsidiary member of a consolidated group for the entire income year, you don't need to complete a return or an IDS.

Label M—Listed country

Show at label M the amount of gross attributed foreign income from listed countries. Listed countries are set out in Part 1 of Schedule 10 to the Income Tax Regulations 1936.

Click labels M or X to use the Foreign Income worksheet (for) to record transactions and calculate any allowable foreign-income tax offset. See Foreign income worksheet (for).

Label X—Unlisted country

Show at label X the amount of attributed foreign income from unlisted countries. Unlisted countries are countries that aren't listed in Schedule 10 to the Income Tax Regulations.

You should also show at label X the amount of income attributed from a transferor trust if the amount isn't shown at labels M.

CCH references

21-100 Scope of CFC rules

21-130 “Listed” countries

21-190 Attribution of CFC income to attributable taxpayers

21-200 Attributable income of a CFC

21-230 Record keeping by attributable taxpayers

21-290 Accruals taxation of non-resident trust income

21-300 Transferor trust measures

21-310 Attributable taxpayers - non-resident trusts

21-360 Foreign investment funds (pre-2010-11)

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