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Foreign hybrids - Where are we now? paper

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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
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Julian Pinson FTI
Julian Pinson, FTI, is a Director at Greenwoods & Herbert Smith Freehills Pty Limited. Julian advises on a wide range of tax matters, with a focus on banking and financial services, 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 26 June 2019
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