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 is a Senior Associate in the Sydney office of Greenwoods & Freehills Pty Limited. Andrew joined Greenwoods & Freehills Pty Limited in January 2004. He advises on a wide range of corporate and banking related tax issues with particular focus on international structures and financial transactions. Andrew has particular experience in the structuring of inbound and outbound investments, cross border transactions and general international tax issues. In particular, Andrew has advised on a range of transactions in the corporate and banking spheres including the structuring of offshore groups and investments, the raising and provision of capital across jurisdictions, stapling arrangements, securitisations and other tax-based financial transactions. Andrew advises a wide range of clients including banks, large corporations, stapled groups and listed property trusts. Prior to moving to Sydney and joining Greenwoods & Freehills, Andrew was a senior tax lawyer in a major London law firm. During his eight years in London, Andrew gained extensive experience in the structuring and implementation of large domestic and international transactions.
Current at 23 August 2007
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