ITAA 1997 s 830-15

Compendium

Permanent Establishment of a US Limited Liability Company

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

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: (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

Permanent establishment of a US Limited Liability Company