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Business income of foreign hybrid exempt

|Approved Changes|Australia
Australia

On 5 September 2008, the Australian Taxation Office released an Interpretative Decision ATO ID 2008/117 confirming that the business income derived by a US LLC, which is treated as a foreign hybrid company for Australian income tax purposes, is non-assessable non-exempt income of the shareholder in the LLC.

By way of background, certain foreign entities transparent for tax purposes in…

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