29 May 09 Joint submission on draft Taxation Ruling TR 2009/d1: Entitlement to foreign income tax offsetsThe Taxation Institute of Australia, the Institute of Chartered Accountants in Australia, the National Institute of Accountants, CPA Australia and Taxpayers Australia have lodged a joint submission on Draft Taxation Ruling TR 2009/D1: Income tax: entitlement to foreign income tax offsets under s 770-10 ITAA 1997 where income is derived from investing in fiscally transparent foreign entities. The professional bodies make three principal submissions on the Draft Ruling, together with some minor additional comments.
The key points raised in the joint submission deal with the following topics:
- investing in a foreign investment fund which is a fiscally transparent entity in the overseas jurisdiction
- investing in a foreign hybrid which is the attributable taxpayer in relation to an underlying CFC or FIF
- the impact of Australia's tax treaties.