10 Sep 09 Partnerships and FIF income - TD 2009/D7
This draft Taxation Determination was issued on 9 September 2009. Its full title is "Income tax: where an Australian resident taxpayer includes its share of the net income of a partnership in its assessable income under s 92 of the ITAA 1936, and the net income of the partnership (as determined in accordance with s 90 of that Act) includes Foreign Investment Fund (FIF) income of the partnership, will that taxpayer be entitled to a FIF exemption under s 519B(2) of that Act for any relevant proportion of their share of the partnership's net income?"
The answer given is No.
For a copy of TD 2009/D7, go here