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Investing off shore into foreign flow - through structures paper

Published on 13 Oct 07 by THE TAX INSTITUTE

This convention paper 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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Current at 22 June 2009 Click here to expand/collapse more articles by Robert GORDON.


This was presented at 46th Victorian State Convention: Feast of Delicacies .

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Individual sessions

Innovative capital raisings

Author(s):  Paul ABBEY

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Corporate distributions and capital management issues

Author(s):  Tim NEILSON

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The Commissioner's Role in Interpreting Tax Law and Emerging Issues for Advisers

Author(s):  Jennifer BATROUNEY

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Defending the trust ramparts

Author(s):  Graeme HALPERIN

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