Published on 19 Sep 18
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- RCF IV structure
- 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.
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
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