Treaty benefits and taxation of partners in limited partnerships holding shares in mining companies
10 Jul 13 |
CCH TAX WEEK
Issue: Issue 25, 28 June 2013
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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Richard Vann, CTA is Challis Professor of Law at the University of Sydney and has taught at Harvard and NYU Law Schools and the Universities of Amsterdam, London and Oxford. Richard has worked in the past at the IMF and OECD and held many Government consultancies in Australia and elsewhere. He has been a consultant for specialist tax firm Greenwoods & Herbert Smith Freehills since 1985. Richard specialises in corporate and international taxation on which he has published widely both in Australia and internationally.
Updated by Kathy Xu for 6th VIC Tax Forum
- Current at
07 May 2018
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