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Session 3.5: Foreign income tax offsets – domestic laws reign supreme

With Amanda Kazacos, King & Wood Mallesons

This session will consider Burton v Federal Commissioner of Taxation [2019] FCAFC 141 - specifically the interaction as between Division 770 of the ITAA and the US-Australia Double Taxation Agreement.

In considering the implications of the Burton case and whether the conclusion was consistent with the intention of Australian taxation law, attendees will obtain a refresher on the operation of the Foreign Income Tax Offset regime as well as further understanding of the policy rationale behind the insertion of the double taxation relief article in Double Taxation Agreements. 

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