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Legislation
ATO documents that consider ITAA 1936 s 94D
27 documents
Goods and services tax: in the application of items 2 and 3 and paragraph (b) of item 4 in the table in subsection 38-190(1) of the A New Tax System (Goods and Services Tax) Act 1999: [bull ] when is a 'non-resident' or other 'recipient' of a supply 'not in Australia when the thing supplied is done'? [bull ] when is 'an entity that is not an Australian resident' 'outside Australia when the thing supplied is done'?
The New Tax System: the meaning of entity carrying on an enterprise for the purposes of entitlement to an Australian Business Number
Income tax: can an unincorporated association of persons acting only in Australia who do not carry on a business in common with a view to profit be a corporate limited partnership within the meaning of section 94D of the Income Tax Assessment Act 1936?
Income tax: is an 'Australian source' in subsection 6-5(3) of the Income Tax Assessment Act 1997 dependent solely on where purchase and sale contracts are executed in respect of the sale of shares in an Australian corporate group acquired in a leveraged buyout by a private equity fund?
Income tax: does the business profits article (Article 7) of Australia's tax treaties apply to Australian sourced business profits of a foreign limited partnership (LP) where the LP is treated as fiscally transparent in a country with which Australia has entered into a tax treaty (tax treaty country) and the partners in the LP are residents of that tax treaty country?
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: the taxation implications of 'partnership salary' agreements
Income tax: Carl Zeiss Vision Group - Manager Equity Investment Program
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
Employee share scheme: whether interests in a corporate limited partnership are ordinary shares
Capital gains tax: scrip for scrip roll-over - Delaware limited partnerships
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
The New Tax System: the meaning of entity carrying on an enterprise for the purposes of entitlement to an Australian Business Number
Income tax: can an Australian-formed unincorporated association of persons who do not carry on a business in common with a view to profit be a corporate limited partnership within the meaning of section 94D of the Income Tax Assessment Act 1936?