Income tax: does 'separate net income' include the imputation credits attached to franked dividends?

TD 94/27 concluded that imputation credits are not included in 'separate net income' as defined in section 159J of the Income Tax Assessment Act 1936 .

Section 159J has been replaced with Subdivision 961-A of the Income Tax Assessment Act 1997 . The concept of 'separate net income' has been replaced with 'adjusted taxable income for offsets'.

TD 94/27 has no ongoing relevance, and is withdrawn without replacement.