ITAA 1997 s 830-30

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

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

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?