The Full Federal Court judgment in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51

8Apr2019

A five-member bench of the Full Federal Court has overturned the first instance decision in Commissioner of Taxation v Resource Capital Fund IV LP [2018] FCA 18.  This judgment will have significant implications for the classification of legal entities for tax purposes, entitlement to treaty benefits and the application of the non-resident capital gains tax in Division 855 for mining and resource companies.

Andrew Broadfoot QC, Gareth Redenbach and James Strong will discuss the decision of the Full Federal Court, how it differs from the judgment at first instance and its implications.

*Please note that drinks will follow in the Library after the seminar.

A five-member bench of the Full Federal Court has overturned the first instance decision in Commissioner of Taxation v Resource Capital Fund IV LP [2018] FCA 18.  This judgment will have significant implications for the classification of legal entities for tax purposes, entitlement to treaty benefits and the application of the non-resident capital gains tax in Division 855 for mining and resource companies.

Andrew Broadfoot QC, Gareth Redenbach and James Strong will discuss the decision of the Full Federal Court, how it differs from the judgment at first instance and its implications.

*Please note that drinks will follow in the Library after the seminar.

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