CofT v Resource Capital Fund IV LP – Comr wins Full Federal Court appeal – US partners in Bermudian limited partnership liable to tax on profit on Australian mining shares

The Full Federal Court has allowed the Commissioner’s appeal against the decision of Pagone J in Resource Capital Fund IV LP v FCT [2018] FCA 41. The Federal Court had allowed an appeal by 2 US private equity limited partnerships in relation to the proper tax treatment of substantial profits made on the sale their shares…