shopping_cart

Your shopping cart is empty

  • Home
  • Foreign hybrids - Where are we now? paper

Foreign hybrids - Where are we now? paper

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 14 Sep 11 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • background to Division 830
  • definition of “foreign hybrid”
  • application of the “foreign hybrid” definition to specific entities
  • partnership treatment of foreign hybrids
  • disposal and cost base issues.

Author profiles

Andrew Hirst CTA
Andrew of Greenwoods & Herbert Smith Freehills, advises on a wide range of corporate and bankingrelated tax issues with a particular focus on financial and international transactions. Andrew has been actively involved in the development of the antihybrid rules. - Current at 29 May 2019
Click here to expand/collapse more articles by Andrew Hirst.
Julian Pinson FTI
Julian Pinson, FTI, is a Partner at Greenwoods & Herbert Smith Freehills Pty Limited. Julian advises on a wide range of tax matters, with a focus on banking and financial services, property, M&A and funds management. Julian has particular expertise in cross-border finance, TOFA, corporate restructures, debt and equity raisings and M&A. - Current at 14 January 2021
Click here to expand/collapse more articles by Julian PINSON.

 

This was presented at International Masterclass .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Renovating the CFC and FIF regimes and rethinking outbound structures

Author(s):  Alison RODI,  Peter MADDEN

Materials from this session:

Renovating the CFC and FIF regimes - Where are we at?

Author(s):  Alison RODI

Materials from this session:

IBM on withholding - What it means

Author(s):  Simon THORP,  Erin Saunders

Materials from this session:

Recent trends in transfer pricing litigation in Australia

Author(s):  Paul MCNAB,  Peter Callejah,  Colin Little

Materials from this session:

Reportable tax positions

Author(s):  Miquel P. TIMMERS

Materials from this session:

Part IVA and international transactions

Author(s):  Robert DEUTSCH

Materials from this session:

Foreign hybrids - Where are we now?

Author(s):  Andrew Hirst,  Julian PINSON

Materials from this session:

Inbounds tips and traps

Author(s):  David SHORT,  Tasha CHUA

Materials from this session:

Further details about this event:

 

Copyright Statement
click to expand/collapse