Published on 14 Sep 11
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
what constitutes a foreign hybrid – TD 2009/2?
basic consequences – partnership treatment
current interaction with s.23AJ, Subdiv 768-G and s.23AH
year to year status of foreign hybrid
part year disposals of interests in foreign hybrids – the problems
FSI reforms – FIF repeal
FSI reforms – future interaction with CFC provisions, s.23AJ, s.23AH and Subdiv 768-G.
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 17 March 2016
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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