ITAA 1997 s 830

Intangibles migration arrangements

Income tax: which country is for the purposes of Part X of the Income Tax Assessment Act 1936 (the Act) the country of residence of a UK Limited Partnership (LP), a US LP, a UK Limited Liability Partnership (LLP) and a US LLP being a non-resident corporate limited partnership within Part III Division 5A of the Act?

Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend when it is paid by a company (not being a Part X Australian resident) to an Australian resident company which receives it in its capacity as a partner in a partnership?

Compendium

Compendium

Income tax: Carl Zeiss Vision Group - Manager Equity Investment Program

Classification of a Bermudan Exempted Limited Partnership for Australian income tax purposes

Foreign hybrid rules: treatment of foreign hybrid company as a partnership

Classification of a United Kingdom limited partnership for Australian income tax purposes

Classification of a German Kommanditgesellschaft for Australian income tax purposes

GST and acquisition of an interest in a Delaware limited liability company

Foreign hybrid company: US limited liability company

Interest withholding tax on interest received by a US Limited Liability Company

Intangibles arrangements

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?

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

Income tax: (a) are credits for United Kingdom interest withholding tax paid allowable under Article 22.1(a) of the 2003 United Kingdom Convention to an Australian resident financial institution which enters into an arrangement of the kind described in Taxpayer Alert TA 2007/3; and (b) would the Commissioner consider the application of Part IVA of the Income Tax Assessment Act 1936 to the arrangement?

Foreign Tax Credits: distributions from a USA Limited Liability Company

Foreign Investment Fund exemption and foreign hybrid

Classification of a Korean Hapja Hoesa for Australian income tax purposes