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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, 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 Click here to expand/collapse more articles by Andrew Hirst.
 

This was presented at International Masterclass.

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