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.
M&A
Capital Gains Tax (CGT)
2018
The RCF Decision - Australian taxation of limited partnerships and the practical implications for investors
Source: New South Wales
Published Date: 19 Sep 2018
Individual Session
The RCF IV Decision - Australian Taxation of limited partnerships, and the practical implications for investors
Author(s):
Andrew Sharp
,
Peter Mccullough CTA
Materials from this
session:
Details
- Published By: Andrew Sharp, Peter Mccullough CTA
- Published On:19 Sep 2018
- Took place at:Four Seasons Sydney, Sydney
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Tags
M&A
Capital Gains Tax (CGT)
2018
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