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A shareholder made a cash contribution to their company to offset losses and prevent dissolution. The DGT has determined that this operation does not constitute a capital loss, but must instead be incorporated into the acquisition value of the shares.
Question posed: Whether the contribution made is considered a capital loss for Personal Income Tax purposes.
Voluntary contributions to a company's equity, made without right to reimbursement or consideration, must be integrated into the acquisition value of the shares. Therefore, the contribution made by a shareholder to offset losses is not considered a capital loss for Personal Income Tax purposes.
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