Your shopping cart is empty
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 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 2019Julian 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
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 MADDENMaterials from this session:
-
insert_drive_file
- insert_chart
- shopping_cart Add all items to cart - $72.00
Renovating the CFC and FIF regimes - Where are we at?
Author(s): Alison RODIMaterials from this session:
-
insert_chart
IBM on withholding - What it means
Author(s): Simon THORP, Erin SaundersMaterials from this session:
-
insert_drive_file
Recent trends in transfer pricing litigation in Australia
Author(s): Paul MCNAB, Peter Callejah, Colin LittleMaterials from this session:
-
insert_drive_file
- insert_chart
- shopping_cart Add all items to cart - $72.00
Reportable tax positions
Author(s): Miquel P. TIMMERSMaterials from this session:
-
insert_chart
Part IVA and international transactions
Author(s): Robert DEUTSCHMaterials from this session:
-
insert_drive_file
- insert_chart
- shopping_cart Add all items to cart - $72.00
Foreign hybrids - Where are we now?
Author(s): Andrew Hirst, Julian PINSONMaterials from this session:
-
insert_drive_file
- insert_chart
- shopping_cart Add all items to cart - $72.00
Inbounds tips and traps
Author(s): David SHORT, Tasha CHUAMaterials from this session:
-
insert_drive_file
- insert_chart
- shopping_cart Add all items to cart - $72.00
Further details about this event:
Copyright Statement