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Foreign hybrids - Where are we now? paper

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
Andrew Hirst is a Senior Associate in the Sydney office of Greenwoods & Freehills Pty Limited. Andrew joined Greenwoods & Freehills Pty Limited in January 2004. He advises on a wide range of corporate and banking related tax issues with particular focus on international structures and financial transactions. Andrew has particular experience in the structuring of inbound and outbound investments, cross border transactions and general international tax issues. In particular, Andrew has advised on a range of transactions in the corporate and banking spheres including the structuring of offshore groups and investments, the raising and provision of capital across jurisdictions, stapling arrangements, securitisations and other tax-based financial transactions. Andrew advises a wide range of clients including banks, large corporations, stapled groups and listed property trusts. Prior to moving to Sydney and joining Greenwoods & Freehills, Andrew was a senior tax lawyer in a major London law firm. During his eight years in London, Andrew gained extensive experience in the structuring and implementation of large domestic and international transactions.
Current at 23 August 2007 Current at 10 April 2013 Click here to expand/collapse more articles by Andrew Hirst.
 
Julian PINSON
Current at 17 October 2011 Click here to expand/collapse more articles by Julian PINSON.

 

This was presented at International Masterclass .

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