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Investing off shore into foreign flow - through structures paper

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Published on 13 Oct 07 by THE TAX INSTITUTE

This convention paper is an examination of issues for portfolio investment in conduit structures in source countries and those in interposed jurisdictions, such as tax havens:

  • Application of tax treaties to conduit entities; Limitation of Benefits articles
  • Conduit entities as "beneficial owners" for treaty purposes (Indofoods case [2006] EWCA CLV 158) 
  • Foreign hybrids LLCs LLPs Div 830
  • Section 485AA election
  • Exemption from FIF for certain US FIF interests
  • Exemption from FIF for complying super funds
  • BOT review of anti-deferral regimes 

Author profile

Robert Gordon CTA
Robert BA LLB LLM FCPA CTA TEP ADIT was first admitted as a lawyer in 1978, and initially worked as an accountant with Big Four firms in Sydney and Melbourne, then as a solicitor in Sydney and Melbourne, becoming a tax partner at lawyers, Corrs Chambers Westgarth. From 1992 he was a member of the NSW Bar specializing in tax, with a special interest in international tax, including offshore trusts and estates. In 2006 he had a one year sabbatical in London where he studied UK and international tax. In 2007 he moved to Melbourne and became a full member of the Victorian Bar. In Nov 2012, after more than 20 years at the NSW and Victorian Bars, he became a consultant at Pointon Partners, Lawyers & Trademark Attorneys. For more articles, see www.robertgordontax.com. - Current at 01 April 2016
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This was presented at 46th Victorian State Convention: Feast of Delicacies .

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Author(s):  Cameron RIDER

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The Commissioner's Role in Interpreting Tax Law and Emerging Issues for Advisers

Author(s):  Jennifer BATROUNEY

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Investing off shore into foreign flow - through structures

Author(s):  Robert GORDON

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Tax Treatment of Beneficial Ownership, Equitable Interests and Absolutely Entitled

Author(s):  Gerry BEAN

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Defending the trust ramparts

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