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Treaty benefits and taxation of partners in limited partnerships holding shares in mining companies

Publication date: 10 Jul 13 | Source: CCH TAX WEEK

Issue: Issue 25, 28 June 2013

Pages: pp1-3


The recent case of Resources Capital Fund III LP v FC of T 2013 ATC 20-386, raises some interesting issues, such as - Partnership issues under the US/Australia tax treaty; Div 855, concerning assets of mining companies; Valuation of Mining information, plants and equipment.

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Author profiles

Prof Richard Vann CTA
Prof Richard Vann, CTA, is Challis Professor of Law at the University of Sydney and a Consultant at Greenwoods & Herbert Smith Freehills. He has also taught at NYU Law School, Harvard Law School and the University of London. He has held many government consultancies in Australia, including the Review of Business Taxation (1998 - 1999), the Review of International Taxation (2002 - 2003) and the Australian Taxation Office Public Rulings Panels on international and indirect taxation (1995-2007). Most recently, he has been involved in various Board of Taxation work on managed investment trusts and collective investment vehicles, the attribution of profits to permanent establishments and as a member of Treasury’s BEPS Advisory Group. Richard is the Editor-in-Chief of the IBFD Global Tax Treaties Commentaries now being progressively published. - Current at 14 July 2017
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Christopher Colley CTA
Chris, CTA, is a Director at Greenwoods & Herbert Smith Freehills. Chris advises corporate and government clients on real estate investments and trusts, as well as share buybacks and international financial transactions. He has wide experience in mergers and acquisitions, cross-border leasing, international bond issues, securitisation, real estate development, structured investment products and GST matters. He is a member of an Australian Taxation Office working group helping to implement new Taxation of Financial Arrangements provisions and also lectures at the University of Sydney. - Current at 17 March 2016
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