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.
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
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