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  Miscellaneous 2007

Investing off shore into foreign flow - through structures

Source: Victoria

Published Date: 13 Oct 2007

 
This presentation is an examination of issues for portfolio investment in conduit structures in source countries and those in interposed jurisdictions, such as tax havens:

  • Application of tax treaties to conduit entities; Limitation of Benefits articles
  • Conduit entities as "beneficial owners" for treaty purposes (Indofoods case [2006] EWCA CLV 158)
  • Foreign hybrids LLCs LLPs Div 830
  • Section 485AA election
  • Exemption from FIF for certain US FIF interests
  • Exemption from FIF for complying super funds
  • BOT review of anti-deferral regimes

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Author(s)

Individual Session

Investing off shore into foreign flow - through structures

Author(s): Robert Gordon
Materials from this session:

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Details

  • Published By: Robert Gordon
  • Published On:13 Oct 2007
  • Took place at:Mantra Erskine Beach Resort, Lorne

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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Miscellaneous 2007

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