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Foreign hybrids - Where are we now? presentation

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.

Author profile

Andrew Hirst CTA
Andrew of Greenwoods & Herbert Smith Freehills, advises on a wide range of corporate and bankingrelated tax issues with a particular focus on financial and international transactions. Andrew has been actively involved in the development of the antihybrid rules. - Current at 29 May 2019
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This was presented at International Masterclass .

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