Federal Commissioner of Taxation v. Energy Resources of Australia Ltd., 94 ATC 4923, [1994] FCA 924 (Full Fed. Ct.)

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Summaries

Summary Under

In order to refinance U.S.-dollar loans that it had received to finance the development of its mine, the Australian taxpayer negotiated a new...

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Summary Under

short-term note facility on capital account

In order to refinance U.S.-dollar loans that it had received to finance the development of its mine, the Australian taxpayer negotiated a new...

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Summary Under

Hill J. stated, in obiter dicta (at p. 4950-4951):

"In my view, where a discounting transaction is conducted wholly in a foreign currency, the...

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