Order for Enforcement of the Income Tax Act

The Securities specified by Cabinet Order prescribed in Article 60-2, paragraph (1) (Special Provisions on Capital Gains upon Departure from Japan) of the Act are the following Securities that are to give rise to the income listed in Article 161, paragraph (1), item (xii) (Domestic Source Income) of the Act:

Specified restricted shares or succeeding restricted shares prescribed in Article 84, paragraph (1) (Value, etc. of Restricted Shares) for which the restriction on transfer prescribed in that paragraph has not been lifted;

Securities representing a right listed in the items of Article 84, paragraph (3) with regard to which the provisions of that paragraph would apply if that right were exercised.

The things specified by Cabinet Order as equivalent to a transfer prescribed in Article 60-2, paragraph (4) of the Act are the transfer or extinguishment of rights corresponding to the amount of money and the value of assets other than money, with regard to the shares, etc. prescribed in Article 37-10, paragraph (2) of the Act on Special Measures Concerning Taxation, based on the grounds prescribed in the items of Article 37-10, paragraph (3) or (4) of that Act or in the items of Article 37-11, paragraph (4) of that Act that gave rise to the delivery of money and assets other than money the sum of whose amount and value is deemed, under Article 37-10, paragraph (3) or (4) (Special Provisions on Taxation of Capital Gains, etc. on General Shares, etc.) or Article 37-11, paragraph (3) or (4) (Special Provisions on Taxation of Capital Gains, etc. on Listed Shares, etc.) of that Act, to be revenue pertaining to capital gains, etc. on general shares, etc. prescribed in Article 37-10, paragraph (1) of that Act or capital gains, etc. on listed shares, etc. prescribed in Article 37-11, paragraph (1) of that Act.

The period specified by Cabinet Order as the period of having a domicile or residence in Japan prescribed in Article 60-2, paragraph (5) of the Act is the following periods:

The period of having a domicile or residence in Japan (excluding the period of residence with a status of residence in the upper column of Appended Table I (Status of Residence) of the Immigration Control and Refugee Recognition Act (Cabinet Order No. 319 of 1951));

With regard to an individual (including the individual's heir) who has received a tax payment grace period under Article 137-2, paragraph (1) (Tax Payment Grace Period Where the Special Provisions on Capital Gains and Similar Income upon Departure from Japan Apply) of the Act (including where it applies under Article 137-2, paragraph (2) of the Act; the same applies hereinafter in this item) with regard to the income tax for the year that includes the day on which the individual made a departure from Japan prescribed in Article 60-2, paragraph (1) of the Act (hereinafter in this Article referred to as "departure from Japan"), the period from that day (where the obligation to pay the income tax subject to deferral prescribed in Article 137-2, paragraph (13) of the Act has been succeeded to under that paragraph, the day of that succession) until the time limit pertaining to that tax payment grace period (limited to the latest of the time limits under Article 137-2, paragraph (1), (5), (8), or (9) of the Act and other provisions specified by Ministry of Finance Order) (excluding the period listed in the preceding item);

With regard to an individual (including the individual's heir) who has received a tax payment grace period under Article 137-3, paragraph (1) or (2) (Tax Payment Grace Period Where the Special Provisions on Capital Gains and Similar Income If Assets Are Transferred to a Nonresident by Gift or Similar Means Apply) of the Act (including where those provisions apply under paragraph (3) of that Article; the same applies hereinafter in this item) with regard to the income tax for the year that includes the day on which the individual received the transfer of the covered assets prescribed in paragraph (1) of that Article by gift, inheritance, or bequest, the period from the day of that gift or the day of the commencement of the succession (where the obligation to pay the income tax subject to deferral prescribed in paragraph (15) of that Article has been succeeded to under that paragraph, the day of that succession) until the time limit pertaining to that tax payment grace period (limited to the latest of the time limits under paragraph (1), (2), (6), (9), or (11) of that Article and other provisions specified by Ministry of Finance Order) (excluding the periods listed in the preceding two items).

The transfers specified by Cabinet Order prescribed in Article 60-2, paragraph (8) of the Act are the following transfers:

A transfer of the Securities and similar interests prescribed in Article 60-2, paragraph (1) of the Act (hereinafter in this Article and the following Article referred to as "Securities and similar interests") that is made at a price lower than the value at the time of the transfer;

A transfer of Securities and similar interests in a case found to result in an unjust reduction of the burden of the income tax for the year that includes the day of the departure from Japan of the individual prescribed in Article 60-2, paragraph (8) of the Act (including the individual's heir) by making that transfer.

The grounds specified by Cabinet Order prescribed in Article 60-2, paragraph (8), item (i) of the Act are the grounds listed in the following items, and the amount calculated as specified by Cabinet Order prescribed in item (i) of that paragraph is the amount calculated by multiplying, by the number of Securities and similar interests for which the transfer or the gift or inheritance with limited liability under item (i) of that paragraph occurred, the amount specified in each of the following items according to the category of the grounds listed in those items that arose with respect to the Securities and similar interests that the individual prescribed in that paragraph held at the time of the departure from Japan (where there are Securities and similar interests acquired after the time of the departure from Japan by the grounds listed in those items, those Securities and similar interests), pertaining to the Securities and similar interests acquired by the grounds listed in those items or held continuously from before the time when those grounds arose; in this case, after the time when those grounds arose with respect to the Securities and similar interests, the amount specified in those items is deemed to be the value at departure from Japan prescribed in those items pertaining to those Securities and similar interests.

A share exchange or share transfer listed in Article 60-2, paragraph (11), item (i) of the Act of a corporation that issued shares (including capital contributions; the same applies hereinafter in this item): the amount specified respectively below according to the category of cases listed below:

In the case of having acquired, by that share exchange, shares of the wholly owning parent corporation in a share exchange or shares of the parent corporation prescribed in Article 167-7, paragraph (4) (Calculation, etc. of Acquisition Price of Shares, etc. Acquired Through a Share Exchange, etc.) (hereinafter in this item referred to as "shares of the parent corporation, etc."), or of having acquired, by that share transfer, shares of the wholly owning parent corporation resulting from a share transfer prescribed in paragraph (6) of that Article: the amount calculated by dividing the value at departure from Japan of the shares issued by the corporation that underwent that share exchange or share transfer (meaning the amount calculated by classifying Securities and similar interests by each different type and issue, and dividing the amount specified in each item of Article 60-2, paragraph (1) of the Act according to the category of cases listed in those items at the time of the departure from Japan of that individual by the number of units of those Securities and similar interests held at the time of that departure from Japan; the same applies hereinafter in this paragraph) by the number of those shares of the parent corporation, etc. or those shares of the wholly owning parent corporation resulting from a share transfer acquired through that share exchange or share transfer per one of those shares (per one unit, for capital contributions);

In the case of not having acquired shares of the parent corporation, etc. by that share exchange: the amount obtained by adding, to the value at departure from Japan of the shares of the parent corporation, etc. pertaining to that share exchange, the amount calculated by multiplying the value at departure from Japan of the shares that ceased to be held due to that share exchange by the number of those shares held at the time of that departure from Japan and dividing the result by the number of shares of the parent corporation, etc. held at the time of that departure from Japan;

The exercise of a right of claim prescribed in Article 60-2, paragraph (11), item (ii) of the Act, the occurrence of the grounds to acquire, the resolution to acquire, or the exercise (hereinafter in this item referred to as the "exercise of a right of claim, etc.") with regard to the shares with a put option, shares subject to call, shares subject to class-wide call, bond with share options, share options subject to call, or bond with share options to which share options subject to call are attached prescribed in that item (hereinafter in this item referred to as "shares with put options, etc."): the amount calculated by dividing the value at departure from Japan of the shares with put options, etc. for which that exercise of a right of claim, etc. occurred by the number of shares (including capital contributions and investment units prescribed in Article 2, paragraph (14) (Definitions) of the Act on Investment Trusts and Investment Corporations; the same applies hereinafter in this paragraph) or share options acquired per one unit of those shares with put options, etc. through that exercise of a right of claim, etc.;

A split or consolidation of shares or of beneficial interests in an Investment Trust or a Specified Trust That Issues Beneficiary Certificates: the amount calculated in accordance with the provisions of Article 110, paragraph (1) or (2) (Acquisition Price of Shares, etc. in the Case of a Share Split or Consolidation) on the basis of the value at departure from Japan of the shares or beneficial interests that underwent that split or consolidation;

A gratis allotment of shares prescribed in Article 111, paragraph (2) (Acquisition Price of Shares Acquired through Allotment to Shareholders) of a corporation that issued shares (limited to a gratis allotment of shares in which shares in the same class of shares as those shares are allotted): the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of the shares that gave rise to that gratis allotment of shares;

A merger prescribed in Article 112, paragraph (1) (Acquisition Price of Shares, etc. Acquired Through a Merger) of a corporation that issued shares: the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of the shares of the merged corporation prescribed in that paragraph pertaining to that merger;

A merger without consideration prescribed in Article 112, paragraph (2) in which the corporation that issued shares is the acquiring corporation prescribed in Article 112, paragraph (1): the amount calculated in accordance with the provisions of Article 112, paragraph (2) on the basis of the value at departure from Japan of the shares of that acquiring corporation pertaining to that merger without consideration;

With regard to the beneficial interests in an Investment Trust, etc. prescribed in Article 112, paragraph (3) (hereinafter in this item referred to as "Investment Trust, etc."), a merger of trusts of the Investment Trust, etc. prescribed in that paragraph: the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of the beneficial interests in the former Investment Trust, etc. pertaining to that merger of trusts;

A company split by split-off prescribed in Article 113, paragraph (1) (Acquisition Price of Shares, etc. Acquired Through a Company Split by Split-Off) of a corporation that issued shares: the amount specified respectively below according to the category of shares listed below:

Shares of the succeeding corporation in a company split prescribed in Article 113, paragraph (1) pertaining to that company split by split-off or shares of the succeeding parent corporation in a company split prescribed in that paragraph: the amount calculated in accordance with the provisions of Article 113, paragraph (1) on the basis of the value at departure from Japan of the shares of the splitting corporation prescribed in Article 61, paragraph (6), item (vi) (Method of Calculating the Amount of Stated Capital, etc. Corresponding to Shares Held, etc.) pertaining to that company split by split-off (hereinafter in (b) and in (b) of the following item referred to as "splitting corporation");

Shares of the splitting corporation pertaining to that company split by split-off that the individual has held continuously since before that company split by split-off: the amount calculated in accordance with the provisions of Article 113, paragraph (3) on the basis of the value at departure from Japan of the shares of that splitting corporation;

A company split by split-off without consideration prescribed in Article 113, paragraph (2) in which the corporation that issued shares is the succeeding corporation in a company split prescribed in Article 113, paragraph (1): the amount specified respectively below according to the category of shares listed below:

Shares of that succeeding corporation in a company split pertaining to that company split by split-off without consideration: the amount calculated in accordance with the provisions of Article 113, paragraph (2) on the basis of the value at departure from Japan of the shares of that succeeding corporation in a company split;

Shares of the splitting corporation pertaining to that company split by split-off without consideration that the individual has held continuously since before that company split by split-off without consideration: the amount calculated in accordance with the provisions of Article 113, paragraph (3) on the basis of the value at departure from Japan of the shares of that splitting corporation;

With regard to beneficial interests in a Specified Trust That Issues Beneficiary Certificates, a trust split of the Specified Trust That Issues Beneficiary Certificates, as prescribed in Article 113, paragraph (6): the amount specified respectively below according to the category of beneficial interests listed below:

The successor trust beneficial interest prescribed in Article 113, paragraph (6) pertaining to that trust split: the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of the beneficial interests in the split trust prescribed in that paragraph pertaining to that trust split (hereinafter in (b) referred to as "split trust");

Beneficial interests in the split trust pertaining to that trust split that the individual has held continuously since before that trust split: the amount calculated in accordance with the provisions of Article 113, paragraph (7) on the basis of the value at departure from Japan of the beneficial interests in that split trust;

A share distribution prescribed in Article 113-2, paragraph (1) (Acquisition Price of Shares, etc. Acquired Through a Share Distribution) of a corporation that issued shares: the amount specified respectively below according to the category of shares listed below:

Shares of the wholly owned subsidiary corporation prescribed in Article 113-2, paragraph (1) pertaining to that share distribution: the amount calculated in accordance with the provisions of paragraph (1) of that Article on the basis of the value at departure from Japan of the shares of the corporation making a distribution in kind prescribed in paragraph (3) of that Article pertaining to that share distribution (hereinafter in (b) referred to as "corporation making a distribution in kind");

Shares of the corporation making a distribution in kind pertaining to that share distribution that the individual has held continuously since before that share distribution: the amount calculated in accordance with the provisions of Article 113-2, paragraph (2) on the basis of the value at departure from Japan of the shares of that corporation making a distribution in kind;

A return of capital or a distribution of residual assets upon dissolution prescribed in Article 114, paragraph (1) (Acquisition Price of Shares, etc. in the Case of a Return of Capital, etc.) of a corporation that issued shares: the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of the shares of that corporation that the individual has held continuously since before that return of capital or distribution of residual assets upon dissolution;

The refund prescribed in Article 114, paragraph (3) of the contribution held prescribed in that paragraph of a corporation: the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of that contribution held in that corporation that the individual has held continuously since before that refund;

With regard to beneficial interests in a Specified Trust That Issues Beneficiary Certificates, the refund of the Specified Trust That Issues Beneficiary Certificates, as prescribed in Article 114, paragraph (4): the amount calculated in accordance with the provisions of that paragraph on the basis of the value at departure from Japan of the beneficial interests in that Specified Trust That Issues Beneficiary Certificates that the individual has held continuously since before that refund;

A distribution of proceeds pertaining to beneficial interests in an Open-Ended Securities Investment Trust (excluding what is paid upon the termination of that Open-Ended Securities Investment Trust or the partial cancellation of that Open-Ended Securities Investment Trust, and limited to a distribution of proceeds that includes the special distribution prescribed in Article 27 (Distributions of Proceeds of Open-Ended Securities Investment Trusts Treated as Nontaxable)): the amount calculated in accordance with the provisions of Article 114, paragraph (6) on the basis of the value at departure from Japan of the beneficial interests in that Open-Ended Securities Investment Trust that the individual has held continuously since before that distribution of proceeds;

An entity conversion prescribed in Article 115 (Acquisition Price of Shares, etc. in the Case of an Entity Conversion) of a corporation that issued shares: the amount calculated in accordance with the provisions of that Article on the basis of the value at departure from Japan of the shares of the corporation that underwent that entity conversion;

A merger, etc. prescribed in Article 116 (Acquisition Price of Share Options, etc. in the Case of a Merger, etc.) in which the corporation that issued share options (including subscription rights for new investment units prescribed in Article 2, paragraph (17) of the Act on Investment Trusts and Investment Corporations; the same applies hereinafter in this paragraph) or bonds with share options is the merged corporation, splitting corporation, wholly owned subsidiary corporation in a share exchange, or wholly owned subsidiary corporation in a share transfer prescribed in that Article: the amount calculated in accordance with the provisions of that Article on the basis of the value at departure from Japan of the share options or bonds with share options of the corporation that underwent that merger, etc.;

The exercise of share options: the amount calculated by dividing the sum of the value at departure from Japan of the share options for which that exercise occurred and the amount of money paid for one of those share options upon the exercise of those share options by the number of Securities and similar interests acquired for one of those share options through the exercise of those share options.

Where calculation is made in accordance with the provisions of Article 110, Article 111, paragraph (2), Article 112, Article 113, paragraphs (1) through (3), (6), and (7), Article 113-2, paragraphs (1) and (2), Article 114, paragraphs (1), (3), (4), and (6), Article 115, and Article 116 pursuant to the provisions of items (iii) through (xvi) of the preceding paragraph, the phrase "acquisition price per share (per unit for capital contributions and investment units; the same applies hereinafter in this Division) of the shares held after the split or consolidation that forms the basis for that calculation is to be the amount calculated by multiplying the previous acquisition price of one old share" in Article 110, paragraph (1) is deemed to be replaced with "value at departure from Japan prescribed in Article 170, paragraph (5), item (iii) (Special Provisions on Capital Gains upon Departure from Japan) (hereinafter referred to as "value at departure from Japan") per share (per unit for capital contributions and investment units; the same applies hereinafter in this Division) of the shares held after the split or consolidation that forms the basis for that calculation is to be the amount calculated by multiplying the previous value at departure from Japan of one old share"; the term "acquisition price" in paragraph (2) of that Article and Article 111, paragraph (2) is deemed to be replaced with "value at departure from Japan"; the phrase "acquisition price per share of the acquired shares of the acquiring corporation (hereinafter in this paragraph referred to as "acquiring corporation shares") or shares of the parent corporation of the acquiring corporation (hereinafter in this paragraph referred to as "shares of the parent corporation of the acquiring corporation") that forms the basis for that calculation is to be the amount calculated by dividing the previous acquisition price of one old share (if there is an amount deemed to have been received as a dividend of surplus, dividend of profits, distribution of surplus, or distribution of monies pursuant to Article 25, paragraph (1), item (i) (Deemed Dividends in the Case of a Merger) of the Act, or an amount of expenses required for the acquisition of those acquiring corporation shares or shares of the parent corporation of the acquiring corporation, the amount obtained by adding the portion of that amount deemed to have been received and that amount of expenses that corresponds to one old share)" in Article 112, paragraph (1) is deemed to be replaced with "value at departure from Japan per share of the acquired shares of the acquiring corporation (hereinafter in this paragraph referred to as "acquiring corporation shares") or shares of the parent corporation of the acquiring corporation (hereinafter in this paragraph referred to as "shares of the parent corporation of the acquiring corporation") that forms the basis for that calculation is to be the amount calculated by dividing the previous value at departure from Japan of one old share"; the phrase "acquisition price per share of the shares held that serves as the basis of that calculation is" in paragraph (2) of that Article is deemed to be replaced with "value at departure from Japan per share of the shares held that serves as the basis of that calculation is", "acquisition price of one of the shares held" with "value at departure from Japan of one of the shares held", "held immediately before that merger without consideration" with "held at the time of the departure from Japan prescribed in Article 60-2, paragraph (1) (Special Provisions on Capital Gains upon Departure from Japan) of the Act", "acquisition price of one old share (meaning" with "value at departure from Japan of one old share (meaning", and "the same applies hereinafter in this paragraph) (where there is an amount deemed to have been received as a dividend of surplus, dividend of profits, or distribution of surplus pursuant to Article 25, paragraph (1), item (i) of the Act, the amount obtained by adding the portion of that amount deemed to have been received that corresponds to one old share)" with "the same applies hereinafter in this paragraph)"; the phrase "acquisition price per unit of the acquired beneficial interest in the consolidated Investment Trust, etc. that serves as the basis of that calculation is the amount calculated by dividing the previous acquisition price of one unit of the old beneficial interest (where there is an amount of expenses required for the acquisition of that beneficial interest in the consolidated Investment Trust, etc., the amount obtained by adding the portion of that amount of expenses that corresponds to one unit of the old beneficial interest)" in paragraph (3) of that Article is deemed to be replaced with "value at departure from Japan per unit of the acquired beneficial interest in the consolidated Investment Trust, etc. that serves as the basis of that calculation is the amount calculated by dividing the previous value at departure from Japan of one unit of the old beneficial interest"; the term "acquisition price" in Article 113, paragraph (1) is deemed to be replaced with "value at departure from Japan", and the phrase "acquired for one of the shares held (where there is an amount deemed to have been received as a dividend of surplus or dividend of profits pursuant to Article 25, paragraph (1), item (ii) (Deemed Dividends in the Case of a Company Split by Split-Off) of the Act, or an amount of expenses required for the acquisition of those shares in the succeeding corporation in a company split or shares in the succeeding parent corporation in a company split, the amount obtained by adding the portion of the amount deemed to have been received and the amount of expenses that corresponds to one share in the succeeding corporation in a company split or one share in the succeeding parent corporation in a company split)" with "acquired for one of the shares held"; the term "acquisition price" in paragraph (2) of that Article is deemed to be replaced with "value at departure from Japan", "held immediately before that company split by split-off without consideration" with "held at the time of the departure from Japan prescribed in Article 60-2, paragraph (1) (Special Provisions on Capital Gains upon Departure from Japan) of the Act", and "amount (where there is an amount deemed to have been received as a dividend of surplus or dividend of profits pursuant to Article 25, paragraph (1), item (ii) of the Act, the amount obtained by adding the portion of that amount deemed to have been received that corresponds to one of the shares held)" with "amount"; the term "acquisition price" in paragraph (3) of that Article is deemed to be replaced with "value at departure from Japan"; the term "acquisition price" in paragraph (6) of that Article is deemed to be replaced with "value at departure from Japan", and the phrase "acquired for one unit of the old beneficial interest (where there is an amount of expenses required for the acquisition of that successor trust beneficial interest, the amount obtained by adding the portion of that amount of expenses that corresponds to one unit of successor trust beneficial interest)" with "acquired for one unit of the old beneficial interest"; the term "acquisition price" in paragraph (7) of that Article is deemed to be replaced with "value at departure from Japan"; the term "acquisition price" in Article 113-2, paragraph (1) is deemed to be replaced with "value at departure from Japan", and the phrase "acquired for one of the shares held (where there is an amount deemed to have been received as a dividend of surplus or dividend of profits pursuant to Article 25, paragraph (1), item (iii) (Deemed Dividends in the Case of a Share Distribution) of the Act, or an amount of expenses required for the acquisition of those wholly owned subsidiary shares, the amount obtained by adding the portion of the amount deemed to have been received and the amount of expenses that corresponds to one wholly owned subsidiary share)" with "acquired for one of the shares held"; the term "acquisition price" in paragraph (2) of that Article and Article 114, paragraphs (1), (3), (4), and (6) is deemed to be replaced with "value at departure from Japan"; the phrase "acquisition price per unit of the acquired new shares that forms the basis for that calculation is to be the amount calculated by multiplying the previous acquisition price of one unit of old shares (if there are expenses required for the acquisition of those new shares, the amount obtained by adding the portion of the amount of those expenses that corresponds to one unit of old shares)" in Article 115 is deemed to be replaced with "value at departure from Japan per unit of the acquired new shares that forms the basis for that calculation is to be the amount calculated by multiplying the previous value at departure from Japan of one unit of old shares"; and the phrase "acquisition price per unit of the acquired acquiring corporation's share options, etc. that forms the basis for that calculation is to be the amount calculated by dividing the previous acquisition price of one unit of former share options, etc. (if there are expenses required for the acquisition of those acquiring corporation's share options, etc., the amount obtained by adding the portion of the amount of those expenses that corresponds to one unit of former share options, etc.)" in Article 116 is deemed to be replaced with "value at departure from Japan per unit of the acquired acquiring corporation's share options, etc. that forms the basis for that calculation is to be the amount calculated by dividing the previous value at departure from Japan of one unit of former share options, etc.".

The grounds specified by Cabinet Order prescribed in Article 60-2, paragraph (11), item (iii) of the Act are the grounds listed in paragraph (5), items (iii) through (v), item (vii), item (viii), item (x), item (x)-2, and items (xv) through (xvii).

Where an individual (including the individual's heir) who is to be subject to the application of Article 60-2, paragraph (1) of the Act for the income tax for the year that includes the day of the departure from Japan has, after the time of that departure from Japan, transferred Securities and similar interests by transfer or by gift or inheritance with limited liability prescribed in Article 60-2, paragraph (8) of the Act, the determination of whether the Securities and similar interests so transferred fall under the Securities and similar interests that the person held at the time of that departure from Japan is to be made on the assumption that the person first transferred or gave Securities and similar interests of the same class acquired after the time of that departure from Japan (excluding, among Securities and similar interests of the same class acquired by gift, inheritance, or bequest, those Securities and similar interests in the case where the person who made the gift or the heir pertaining to the inheritance or bequest is subject to the application of Article 137-3, paragraph (1) or (2) of the Act for the income tax for the year that includes the day of the gift or the day of the commencement of the succession (hereinafter in this paragraph referred to as "Securities, etc. with deferred tax")), and next transferred or gave, in order, starting from those to which the provisions of Article 60-2, paragraph (1) or Article 60-3, paragraph (1) (Special Provisions on Capital Gains upon Transfer of Assets to a Nonresident by Gift or Similar Transfer) of the Act applied earlier, the Securities and similar interests that the individual held at the time of that departure from Japan or the Securities, etc. with deferred tax.

Where the grounds listed in the items of Article 60-2, paragraph (11) of the Act arise with respect to the Securities and similar interests held by the individual prescribed in the preceding paragraph (hereinafter in this paragraph referred to as "former Securities and similar interests"), and the Securities and similar interests acquired by those grounds (hereinafter in this paragraph referred to as "acquired Securities, etc.") are deemed, under Article 60-2, paragraph (11) of the Act, to have been continuously owned, the provisions of the preceding paragraph apply by treating the portion of those former Securities and similar interests that gave rise to the acquisition of those acquired Securities, etc. as Securities and similar interests of the same class as those acquired Securities, etc.