Burton v Commissioner of Taxation, [2019] FCAFC 141 -- summary under Article 24
“income” was the full U.S. gain, but FTC to be calculated based on Australian (1/2 recognition) principles
An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 91 - Subsection 91(4) | credit “in respect of” income only included the taxable ½ of capital gain | 212 |