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Investing offshore into foreign flow-through vehicles paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 15 Feb 07 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This paper provides:

  • a technical overview of the foreign hybrid provisions in Australian income tax law
  • comparison of the key Australian income tax implications of investing in a CFC or FIF to investing in a foreign hybrids
  • several contentious areas in relation to the practical application and operation of the foreign hybrid provisions.

Author profile

Norah SEDDON
Norah is a Partner in PricewaterhouseCoopers’ International Tax and Transaction Services team and is based in Sydney. She has over 14 years’ experience with PricewaterhouseCoopers. Norah specialises in cross-border taxation planning and structuring and in both international and domestic mergers and acquisitions. Her clients include Australian multinational groups with foreign investments, foreign multinational groups with both Australian strategic and private equity investments and Australian trusts and other investors with foreign investments.
Current at 12 December 2006
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This was presented at 2007 Financial Services Taxation Conference: Financial Services Unleashed .

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Investing offshore into foreign flow-through vehicles

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