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How is source determined? paper


This paper covers:

  • why is the determination of the source of income important?
  • when does the determination of source become critical?
  • what is the meaning of "source" of income?
  • what is the meaning of Australia and what is its impact on the determination of “source”?
  • what is the “source” of business income and trading income?

Please note this paper was originally presented by Cory Hillier at An Introduction to Australia's International Taxation Sytem in Sydney on the 18th August and has been updated by Kai-Chen Chang.

Author profiles

Kai-Chen Chang
Kau-Chen is a Senior Associate at Mallesons Stephen Jaques based in the Melbourne office. Kai-Chen specialises in income tax with an emphasis on the taxation of trusts, cross-border investment and other corporate issues and transactions. She has had significant experience in advising clients in the funds management industry on the establishment, operation and restructure of funds and on reviewing and drafting the associated documentation. - Current at 26 August 2011
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Cory Hillier CTA
Photo of author, Cory HILLIER Cory is a Senior Associate in the Taxation Group at King & Wood Mallesons. He specialises in tax with a focus on corporate tax. His practice concentrates on providing tax advice to a variety of financial institutions, as well as to large domestic and multinational corporations. He has extensive experience in funds management, structured and financial products, banking and finance, and mergers and acquisitions transactions. Cory was recently named as an associate to watch in the 2012 Chambers: Asia Pacific client guide. - Current at 18 February 2013
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This was presented at An Introduction to Australia's Taxation System .

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Individual sessions

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International withholding taxes

Author(s):  Peter B STINSON,  Paul KORGANOW

Materials from this session:

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