The taxpayer has appealed to the Federal Court from the decision in Hamilton and FCT [2020] AATA 1812, which upheld the Commissioner’s ruling that the taxpayer’s income from short-term assignments with the International Monetary Fund (IMF) was not exempt from tax under the International Organisations (Privileges and Immunities) Act 1963. The tests in the High Court case of CofT v Jayasinghe [2017] HCA 26 were applied.
See below for details.