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Legislation
ATO documents that consider ITAA 1936 s 5 of Part III
26 documents
Application of General Anti-Avoidance Rules
Income tax: aggregated turnover - application of the 'connected with' concept to corporate limited partnerships
Income tax: aggregated turnover - application of the 'connected with' concept to partnerships, foreign hybrids and non-entity joint ventures
Income tax: Non-commercial losses - application of subsections 35-10(2) and 35-10(4) of the Income Tax Assessment Act 1997 to business activities carried on in partnership.
Income tax: the taxation implications of 'partnership salary' agreements
Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities
Symbio Holdings Limited - scrip for scrip roll-over and special dividend
Platinum Asia Investments Limited - disposal of shares and special dividend
AVJennings Limited - scheme of arrangement and special dividend
Accessing business profits through an interposed partnership with a private company partner
Purported tax-exempt non-profit 'foundations' used to evade or avoid taxation obligations
Income tax: Film Investment - 'Extreme'
Income tax: Film Investment - 'Hell for Leather'
Income tax: Film Investment - 'Show Ring'
Foreign hybrid rules: treatment of foreign hybrid company as a partnership
Permanent Establishment of a US Limited Liability Company
Application of section 295-85 of the ITAA 1997: where a complying superannuation fund is a partner in a venture capital limited partnership
Interest withholding tax on interest received by a US Limited Liability Company
Application of General Anti-Avoidance Rules
Income tax: where an Australian resident taxpayer includes its share of the net income of a partnership in its assessable income under section 92 of the Income Tax Assessment Act 1936, and the net income of the partnership (as determined in accordance with section 90 of that Act) includes Foreign Investment Fund (FIF) income of the partnership, will that taxpayer be entitled to a FIF exemption under subsection 519B(2) of that Act for any relevant proportion of their share of the partnership's net income?