Resource Capital Fund IV LP v CofT – US private equity funds, structured as Caymans limited partnerships, not taxed on profit from sale of shares in Australian Lithium mining and processing company

On 5 February 2018, the Federal Court set aside the Commissioner’s assessments, issued to two limited partnerships, for profits they made on their respective investments in the shares of an Australian mining company: Talison Lithium Limited (Lithium Co). In 2007, two limited liability partnerships: Resource Capital Fund IV LP (Resource IV) and Resource Capital Fund…