On Thursday 21 Nov 2019, the ATO issued TD 2019/D12 – which asks the question: ‘is section 951A of the US Internal Revenue Code a provision of a law of a foreign country, that corresponds to section 456 or 457 of the Income Tax Assessment Act 1936 (ITAA36) for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997 (ITAA97) – which is part of our ‘Hybrid Mismatch’ rules?

See below for a summary of the determination.

[Tax Month – November 2019]

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