The High Court has refused the taxpayer’s application for special leave to appeal against the Full Federal Court decision in FCT v Resource Capital Fund III LP [2014] FCAFC 37. In that case, the Full Court unanimously allowed the Commissioner’s appeal and held that the taxpayer, a non-resident limited partnership, was assessable on a capital gain of $58m it made on the sale of shares it held in an Australian company that carried out mining operations in Australia.
[LTN 203, 21/10/14]