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Jane Michie FTIA (Greenwoods and Freehills) represented the Taxation Institute at the NTLG Foreign Source Income meeting held on Tuesday 25 November 2008. In addition to updates on the international Rulings Program and the Sub-group's issues register, discussions at the meeting focused on:

  • a number of foreign hybrid technical issues (including what is meant by ‘foreign tax is imposed’ for the purposes of the definition of foreign hybrid partnership in section 830-10, the lodgment of partnership returns, the interaction of Division 830 with the FTC and FTO regimes, and the exemptions under the FIF regime); and
  • foreign income tax offsets (including the application of s 770-75 to debt deductions, and the ‘reasonably related’ test in calculating the FITO limit under s 770-75).

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