Federal Revenue recognizes non-incidence of income tax on donation of closed FIA quotas

In a recent solution to a consultation, the Federal Revenue recognized that income tax is not levied on the donation, at cost value, of quotas in closed stock investment funds (FIA), made for legitimate purposes.

The line of reasoning adopted by the tax authorities was that any capital gain should be determined in cases where the donation of quotas is made for an amount higher than the acquisition cost and, upon redemption or other liquidity event – ​​e.g.; amortization –, if and when calculated.

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