15 May 077 Taxpayer alert: Foreign tax credit enhanced return bond investment - TA 2007/3On 14 May 2007, the ATO issued Taxpayer Alert TA 2007/3 entitled "Income Tax: Foreign tax credit enhanced return bond investment. The Taxpayer Alert describes an arrangement where an Australian resident taxpayer seeks to enhance its return on a bond investment, through access to foreign tax credits for withholding tax claimed to be payable under the arrangement. The desired net effect of the arrangement is that neither the bond issuer group, nor the Australian resident taxpayer, bears the economic cost of the tax withheld.
In a media release issued on 14 May 2007, the Commissioner, Michael D’Ascenzo, said the arrangement or variations are mainly marketed to financial institutions. The ATO is examining these arrangements.
For a copy of TA 2007/3, go here
For a copy of the ATO media release, No Nat 2007/16, 14 May 2007, go here