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Foreign hybrids - Beware of the thorns

Published on 01 Aug 06 by "THE TAX SPECIALIST" JOURNAL ARTICLE

It has now been two years since the foreign hybrid rules were enacted. As Australian foreign investment has expanded and different investment structures have proliferated, a number of issues have been identified with the rules. This paper provides an overview of the rules and discusses some of the issues that arise.

Author profiles:

Mark HADASSIN
Mark is a Partner in the International Tax & Transaction Services Group in the Sydney office of PricewaterhouseCoopers. Mark has over 12 years experience in corporate and international taxation and has also worked in the United States. Mark specialises in international tax and regularly advises clients on taxation issues arising from M&A transactions, cross-border financing arrangements and corporate restructures.
Current at 23 August 2006 Current at 25 June 2013 Click here to expand/collapse more articles by Mark HADASSIN.
 
Sarah Saville
Current at 28 August 2006

 

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