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A foreign hybrid is an entity that was taxed in Australia as a company but taxed overseas as a partnership. This can include a limited partnership, a limited liability partnership and a United States limited liability company.
If you have an investment in a foreign hybrid (referred to as being a member of a foreign hybrid), you are treated for Australian tax purposes as having an interest in each asset of the partnership.
As a consequence, any capital gain or capital loss made with respect to a foreign hybrid or its assets is taken to be made by the member. See www.ato.gov.au for more information.
Last modified: 29 Jun 2011QC 28011