ITAA 1997 s 6-10(5)(b)

The basis for including an employment termination payment in the assessable income of a foreign resident

Alienation of personal services income of a foreign resident and the interaction with the core provisions for assessable income

Assessable income: personal services income attributed to a non-resident under Part 2-42 of the ITAA 1997 - no double tax agreement applies

Assessability of an employment termination payment paid to a foreign resident

Employee Share Scheme: taxation of the discount on the exercise of share rights by a resident of the United States where the rights relate to employment exercised in and out of Australia while the taxpayer was an Australian resident