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Taxation of Foreign Hybrids - clarity and sanity

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Published on 01 Feb 04 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Whilst limited partnerships and limited liability companies have become the vehicle of choice for investing into many countries, Australian tax law has provided a significant risk of global double taxation. Thankfully, the law is to be clarified to eliminate this possibility.

This paper was also presented at the International Masterclass held in Sydney on 22 July 2003.

Author profile

Neil Billyard CTA
Neil is a Partner in International Corporate Tax at KPMG. Neil has over 22 years corporate tax experience and specialises in foreign merger and acquisition activities of Australian multi-nationals, cross-border funding, the repatriation of profits and other related structuring. He is actively involved in working with Treasury and government on a variety of international tax reform issues, including assisting with policy development and drafting of legislation. He has lectured the Master of Laws/Tax course at the University of Sydney and is a regular presenter for The Tax Institute. - Current at 01 February 2011
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