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See Also
Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51
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| Tax Topics - Treaties - Income Tax Conventions - Article 13 | exclusion in Art. 13 of Aust.-U.S. Treaty for real property dispositions extended to shares of Australian holding company holding mining leases through grandchild |
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | private equity fund LP with 5-year holding objective realized share gain on income account | 167 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | gains of a NR PE fund from disposals of Australian share investments that were managed in part in Australia were derived from Australia | 411 |
| Tax Topics - Treaties - Income Tax Conventions - Article 3 | each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise” | 222 |
| Tax Topics - General Concepts - Stare Decisis | lower court not bound by a point of law that was assumed rather than examined by a higher court | 272 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | assessment of partnership was assessment of partners | 83 |
| Tax Topics - Treaties - Income Tax Conventions - Article 6 | Art. 6 extends common law meaning of real property | 180 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d) | shares of lithium mining and processing company were derived principally from the processing rather than mining operation and, thus, were not taxable Australian real property | 500 |
| Tax Topics - Income Tax Act - Section 218.3 - Subsection 218.3(1) - Canadian Property Mutual Fund Investment | shares of Australian mining company were primarily attributable to the processing rather than mining operations | 140 |
| Tax Topics - General Concepts - Fair Market Value - Other | processing assets of mining company were more valuable than its mining assets | 234 |
Administrative Policy
7 October 2011 Roundtable, 2011-0411951C6 F - Retenues à la source - options d'achat d'actions
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| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.01) | treatment of net share issuances under review |
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| Tax Topics - Income Tax Regulations - Regulation 6204 - Subsection 6204(1) - Paragraph 6204(1)(a) | conferral on employer of share repurchase right to set off against source deduction obligation engages the exclusion | 63 |
| Tax Topics - Income Tax Regulations - Regulation 6204 - Subsection 6204(1) - Paragraph 6204(1)(b) | loss of prescribed share status where employer granted redemption right to cover s. 153(1.01) withholding obligations | 110 |