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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, CTA, is a Director at Greenwoods & Herbert Smith Freehills Pty Limited. Andrew advises on a wide range of corporate and banking-related tax issues with a particular focus on financial and international transactions. Andrew has been extensively involved in the development of the TOFA provisions and represented The Tax Institute before the House of Representatives Economic Committee in relation to recent changes in this area. - Current at 10 April 2017
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Julian Pinson FTI
Julian is a Senior Associate at Greenwoods & Herbert Smith Freehills Pty Limited. He advises on the domestic and international tax aspects of a wide range of matters for clients, primarily in the finance, infrastructure, property and funds management sectors. He has been involved in advising on the tax aspects of corporate acquisitions and reorganisations, cross-border financing transactions, financial products and capital raisings. - Current at 13 November 2014
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