The Resource Resource Capital Fund III : a Canadian perspective on applying a treaty to a hybrid partnership

Resource Capital Fund III : a Canadian perspective on applying a treaty to a hybrid partnership

Label
Resource Capital Fund III : a Canadian perspective on applying a treaty to a hybrid partnership
Title
Resource Capital Fund III : a Canadian perspective on applying a treaty to a hybrid partnership
Creator
Subject
Language
eng
Summary
On 26 April 2013, the Australian Federal Court handed down its decision in Resource Capital Fund III LP v. Commissioner of Taxation (RCF). This case, which involved a private equity fund realizing a gain on the sale of shares of an Australian mining company, was eagerly expected as, among other things, it raises important issues of tax treaty law that are of interest to international tax practitioners in Australia and abroad. This article provides a Canadian perspective on the tax treaty matters discussed in RCF. In particular it discusses the following four questions: Can a tax treaty settle a procedural or administrative issue?; What is the relevance of OECD commentaries in interpreting a tax treaty?; When is a hybrid partnership a treaty resident?; When is it appropriate to look through a hybrid partnership in applying a tax treaty?
Citation source
In: Tax notes international. - Falls Church. - Vol. 70 (2013),
http://library.link/vocab/creatorName
  • Kandev, M.N
  • Milet, M
Language note
English
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • treaty interpretation
  • partnership
  • looking through
Label
Resource Capital Fund III : a Canadian perspective on applying a treaty to a hybrid partnership
Instantiates
Publication
Label
Resource Capital Fund III : a Canadian perspective on applying a treaty to a hybrid partnership
Publication

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