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  Miscellaneous 2007

Investing off shore into foreign flow - through structures

Source: Victoria

Published Date: 13 Oct 2007

 

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This convention paper is an examination of issues for portfolio investment in conduit structures in source countries and those in interposed jurisdictions, such as tax havens:

  • Application of tax treaties to conduit entities; Limitation of Benefits articles
  • Conduit entities as "beneficial owners" for treaty purposes (Indofoods case [2006] EWCA CLV 158) 
  • Foreign hybrids LLCs LLPs Div 830
  • Section 485AA election
  • Exemption from FIF for certain US FIF interests
  • Exemption from FIF for complying super funds
  • BOT review of anti-deferral regimes 
Author(s)

Individual Session

Investing off shore into foreign flow - through structures

Author(s): Robert Gordon CTA
Materials from this session:

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Details

  • Published By: Robert Gordon CTA
  • Published On:13 Oct 2007
  • Took place at:Mantra Erskine Beach Resort, Lorne

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