International tax & business 2018

Is your entity a foreign hybrid entity?

Source: The Tax Specialist Journal Article

Published Date: 1 Apr 2018


Many countries were not blessed with trust law. In order to participate in the global economy, Australians must understand and utilise a range of investment structures which do not always easily interface with the Tax Act. The concept of the foreign hybrid entity was intended to allow Australians to grapple with these investment vehicles, by accommodating and making sense of a range of popular outbound entity types. With recently renewed doubt around the exact nature of corporate limited partnerships, the foreign hybrid category may be of renewed interest to investors and their advisers. This article sets out the cause and consequences of the foreign hybrid entity regime (with a particular focus on foreign hybrid limited partnerships), and identifies that significant work remains before this regime can truly offer investors the kind of certainty that it was intended to bring.

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International tax & business 2018

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