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The RCF Decision – Australian taxation of limited partnerships and the practical implications for investors presentation


This presentation covers:

  • RCF IV structure
  • facts
  • RCF III decision
  • key issues
  • who was the relevant taxpayer?
  • source of gains
  • US/AU DTA and fiscally transparent entities
  • Article 13 of the DTA and Division 855.

Author profiles

Andrew Sharp
Andrew is a Partner in the Transaction Tax team at EY, focused on M&A, as well as fund establishment and design. Andrew has over 14 years’ experience advising domestic fund managers on the raising of funds, as well as assisting foreign and domestic investors on the tax implications of transacting in Australia. - Current at 11 February 2021
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Peter McCullough
Peter is the Global Practice Head Tax of Ashurst based in Sydney. Prior to joining Ashurst in 2010, Peter was a partner in the tax practice of Ernst & Young. He has over 27 years of experience advising on a wide range of Australian and international income tax matters, dealing with clients across a broad range of industries. Peter has presented at conferences in Australia and overseas on domestic and international tax issues, is an author of the LexisNexis publication Corporate Tax: Finance, Transactions, Distributions, and has written articles and tax commentary in a number of other professional publications. - Current at 01 June 2015
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This was presented at International Masterclass 2018 .

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