part 3

part 3 is here and part 4 is 26th July composition. In addition, in case of U.S., these sophisticated anti-avoidance rules are prepared on the assumption that the systems like “Capital Account" based on the real economic substantiality among partners apart from the "Outside Basis" devised only for the tax purpose are introduced, and special allocation agreements are allowed on based of this capital account concept. If this concept of Capital Account is built on the foundation of Chinese partnership tax system, the application is possible, but otherwise it seems to be difficult to apply theses rules in China.

Here's the continuation. Please check.

Part 3 is here and part 4 is 26th July composition.

>> Correct.
In addition, in case of U.S., these sophisticated anti-avoidance rules are prepared on the assumption that the systems like “Capital Account" based on the real economic substantiality among partners apart from the "Outside Basis" devised only for the tax purpose are introduced, and special allocation agreements are allowed on based of this capital account concept.

>> Correct.

If this concept of Capital Account is built on the foundation of Chinese partnership tax system, the application is possible, but otherwise it seems to be difficult to apply theses rules in China.

>> If this concept of Capital Account is built on the foundation of Chinese partnership tax system, the application is possible, otherwise it seems to be difficult to apply these rules in China.