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Australian Full Federal Court Holds Foreign Limited Partnership Liable to Tax; Reversing Earlier Decision

|Treaty Development|Australia-United States-Cayman Islands
Australia-United States-Cayman Islands

On 2 April 2019, the Full Federal Court of Australia issued its judgment concerning the treatment of limited partnerships in the Cayman Islands with U.S. partners. In 2013, the partnerships realized gains on the disposal of shares in an Australian mining company, for which tax assessments were issued. The assessments were appealed, with the primary judge finding that the assessments were exces…

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