Australia's ongoing resources boom has attracted a great deal of foreign investment into our equity capital markets, some of which has been sourced from global resources companies, and some from global investment funds (including foreign governments' sovereign wealth funds). The recent downturn in global credit and equity markets makes it quite timely to consider what tax principles might apply to the divestment of such investments. This paper covers:
institutional investors - rethinking the capital/revenue distinction in a post-CGT environment
the source of income from Australian investments
applying the tracing rules to identify taxable Australian property
international tax aspects of scrip-for-scrip rollovers and demergers
sovereign wealth funds.
Duncan is a Partner at Blake Dawson. He was previously a Partner in the International Tax Group of a global accounting firm. Duncan served as one of the three private sector representatives on the Federal Government’s Tax Design Review Panel.
- Current at
05 May 2009
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