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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.
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
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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