01 Oct 09 FITO: s 770-10 & fiscally transparent foreign entities - TR 2009/6
This final Taxation Ruling was issued on 30 September 2009. It was previously released in draft form as TR 2009/D1. Its full title is "Income tax: entitlement to foreign income tax offsets under s 770-10 of ITAA 1997 where income is derived from investing in fiscally transparent foreign entities".
A foreign entity is fiscally transparent if no foreign income tax is imposed on its income, either by effect of application of the laws of a foreign country or because of an election, but rather tax is imposed on such income at the level of the partner or member.
For a copy of TR 2009/6, go here