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Article 37 outlines the taxation rules for partners in a partnership. It specifies that a partner's share of the partnership's income, deductions, losses, and debt retains its original character, including its geographic source and type, when determining the partner's tax base. A partner must account for their share in the taxable year in which the partnership's year concludes. Crucially, any loss exceeding the partner's cost base is suspended until a sufficient base is acquired or the partner's share is disposed of. The Article clarifies that the related-party loss disallowance rule under Article 63(d) is not applicable.
Chapter 8 - Taxation Rules of Partnerships
Article 37 - Taxation on Partners
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