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

Published on 19 Sep 18 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

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

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
Click here to expand/collapse more articles by Peter MCCULLOUGH.
Andrew Sharp
Andrew Sharp is an EY Tax Partner who helps domestic managers raise funds, and helps both offshore and domestic fund managers invest them. - Current at 10 June 2019
Click here to expand/collapse more articles by Andrew SHARP.

 

This was presented at International Masterclass 2018 .

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