Taxation Determination

TD 2009/2A1 - Addendum

Income tax: when is 'foreign income tax... imposed... on the partners, not the partnership' under paragraph 830-10(1)(b) of the Income Tax Assessment Act 1997 for the purpose of determining whether a foreign limited partnership is a foreign hybrid limited partnership under Division 830 of that Act?

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Addendum

This Addendum amends Taxation Determination TD 2009/2 to reflect that the Tax Laws Amendment (Foreign Source Income Deferral) Act (No. 1) 2010 has repealed Part XI of the Income Tax Assessment Act 1936.

TD 2009/2 is amended as follows:

1. Footnote 7

Omit 'Part XI of the ITAA 1936'; substitute 'Former Part XI of the ITAA 1936. Part XI was repealed by Tax Laws Amendment (Foreign Source Income Deferral) Act (No 1) 2010.'

This Addendum applies on and from 14 July 2010.

Commissioner of Taxation
3 April 2013

References

ATO references:
NO 1-2TW3S31