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Legislation
ATO documents that consider ITAA 1936 s 5A
20 documents
ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions
Income tax: when is 'foreign income tax... imposed... on the partners, not the partnership' under paragraph 830-10(1)(b) of the Income Tax Assessment Act 1997 for the purpose of determining whether a foreign limited partnership is a foreign hybrid limited partnership under Division 830 of that Act?
Income tax: can a foreign resident elect to treat their interest in a limited partnership as an interest in a foreign hybrid limited partnership under paragraph 830-10(2)(b) of the Income Tax Assessment Act 1997 ?
Income tax: the taxation implications of 'partnership salary' agreements
Arrangements designed to avoid the operation of Division 7A through the use of a Corporate Limited Partnership
Interest on debentures issued by a limited partnership and the definition of a 'company' for the purposes of the interest withholding tax exemption
Interest on debentures issued by a limited liability partnership and the meaning of 'resident of Australia' for the purposes of the interest withholding tax exemption
Classification of a Bermudan Exempted Limited Partnership for Australian income tax purposes
CGT event A1: partnership becomes corporate limited partnership
US Limited Partnership: whether it is a company for the purposes of Article 10 of the US Convention
Foreign tax credits: distributions from a USA Corporate Limited Partnership to a foreign hybrid limited partnership - section 160AF of the ITAA 1936
Foreign income tax offsets: distributions from a USA Corporate Limited Partnership to a foreign hybrid limited partnership - section 770-10 of the ITAA 1997
ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions
ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions
Income tax: can a foreign resident elect to treat their interest in a limited partnership as an interest in a foreign hybrid limited partnership under paragraph 830-10(2)(b) of the Income Tax Assessment Act 1997?
Income tax: aggregated turnover - application of the 'connected with' concept to corporate limited partnerships
Partner Salary in A Corporate Limited Partnership
Debt/Equity Borderline: the characterisation of a priority partnership interest issued by a corporate limited partnership
Classification of a Korean Hapja Hoesa for Australian income tax purposes
Foreign Investment Fund exemption and foreign hybrid