This presentation covers:
- RCF IV structure
- facts
- RCF III decision
- key issues
- who was the relevant taxpayer?
- source of gains
- US/AU DTA and fiscally transparent entities
- Article 13 of the DTA and Division 855.
Source: New South Wales
Published Date: 19 Sep 2018
This presentation covers:
More by Andrew Sharp
Demergers and capital management update - Audio 20 May 2021
Demergers and capital management update - Paper 20 May 2021
Demergers and capital management update - Video 20 May 2021
Demergers and capital management update - Presentation 20 May 2021
Current issues in M&A and capital management - Paper 11 Mar 2020
MA and capital management - Presentation 11 Mar 2020
The RCF IV Decision - Australian Taxation of limited partnerships, and the practical implications for investors - Paper 19 Sep 2018
Withholding tax and foreign tax fundamentals - Presentation 27 Apr 2016
Current taxation issues in M&A - Paper 30 Oct 2012
More by Peter Mccullough
The RCF IV Decision - Australian Taxation of limited partnerships, and the practical implications for investors - Paper 19 Sep 2018
Issues facing parents and subsidiaries in the current international tax climate - Journal 01 Jun 2015
Issues facing parents and subsidiaries in the current international tax climate - Presentation 18 Mar 2015
Issues facing parents and subsidiaries in the current international tax climate - Paper 18 Mar 2015
Managing debt rights and obligations"Some key tax issues - Presentation 06 Nov 2008
Dealing with rights and obligations under contractual arrangements"Rescheduling or cancellation - Paper 06 Nov 2008
International tax reform - changes to the foreign income, CFC and capital gains tax rules - Presentation 22 Sep 2004
International tax reform - changes to the foreign income, CFC and capital gains tax rules seminar - Paper 22 Sep 2004
Foreign Investment - Paper 31 Aug 2000
Individual Session
Details
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
("TTI")
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
Tags