ITAA 1997 s 974-135

Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia

Income tax: the relevance of 'economic compulsion' in deciding whether an issuer of a financing arrangement has an 'effectively non-contingent obligation' for the purposes of section 974-135 of the Income Tax Assessment Act 1997

Compendium

DBG Global Enterprises Pty Ltd - customer equity scheme

Debt/Equity: whether short term trade finance gives rise to debt interest under Division 974

Debt/Equity: Redeemable Preference Share

Redeemable preference shares: debt interest under Division 974

Debt/Equity financing: unsecured notes that may be converted into preference shares

Division 974: application of the debt test to Certificates of Deposit

Income tax: ascertaining the right to tax US and UK resident financial institutions under the United States and the United Kingdom Double Taxation Conventions in respect of interest income arising in Australia

Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia

Income tax: the relevance of 'economic compulsion' in deciding whether an issuer of a financing arrangement has an 'effectively non-contingent obligation' for the purposes of section 974-135 of the Income Tax Assessment Act 1997

Debt/Equity Borderline: the characterisation of a priority partnership interest issued by a corporate limited partnership