This presentation covers:
- RCF IV structure
- facts
- RCF III decision
- key issues
- who was the relevant taxpayer?
- source of gains
- US/AU DTA and fiscally transparent entities
- Article 13 of the DTA and Division 855.
maintenance
M&A
Capital Gains Tax (CGT)
2018
The RCF Decision " Australian taxation of limited partnerships and the practical implications for investors
Source: New South Wales
Published Date: 19 Sep 2018
Individual Session
The RCF IV Decision - Australian Taxation of limited partnerships, and the practical implications for investors
Author(s):
Andrew Sharp
,
Peter Mccullough
Materials from this
session:
Details
- Published By: Andrew Sharp, Peter Mccullough
- Published On:19 Sep 2018
- Took place at:Four Seasons Sydney, Sydney
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.
Tags
M&A
Capital Gains Tax (CGT)
2018
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