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Foreign investment in Australian securities paper

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Published on 22 Sep 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • what is the continuing relevance of the capital/income distinction?
  • how do our source rules apply to the typical range of investments?
  • what has been the administrative practice of the ATO to date?
  • what is the relevance of FIN 48?
  • why do we need an investment manager regime (IMR)?
  • proposals for reform (I): introduce statutory exception to common law souce rules
  • proposals for reform (II): introduce a IMR.

Author profile

John King CTA
John is a Consultant at Prolegis Lawyers in Sydney. Prolegis is a 10 lawyer boutique firm that specialises in advising clients throughout Australia in relation to the charities and not-for-profits sector (including structuring, establishment, tax, regulatory, governance and other compliance, fundraising, grant making, employment law, mergers & other restructures, and disputes). Prior to joining Prolegis in 2011, John was a Tax Partner at Mallesons Stephen Jaques (now King&Wood Mallesons) in Sydney and New York for more than 31 years. - Current at 27 June 2016
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