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Legislation
ATO documents that consider ITAA 1997 s 2 and Schedule 2A (the US Convention) to the International Tax Agreements Act 1953 (Agreements Act) in respect of a capital gain which arises from the disposal of shares in an Australian public company which were acquired while the taxpayer was a resident of Australia but disposed of while the taxpayer was a United States (US) resident, where the taxpayer made a choice under subsection 104-165(2)