Taxation Determination

TD 93/160

Income tax: Foreign Income (FI) Cell: what is the purpose of the FI Cell and what are its objectives?

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FOI status:

may be releasedFOI number: I 1215894

This Determination, to the extent that it is capable of being a 'public ruling' in terms of Part IVAAA of the Taxation Administration Act 1953 , is a public ruling for the purposes of that Part. Taxation Ruling TR 92/1 explains when a Determination is a public ruling and how it is binding on the Commissioner. Unless otherwise stated, this Determination applies to years commencing both before and after its date of issue. However, this Determination does not apply to taxpayers to the extent that it conflicts with the terms of a settlement of a dispute agreed to before the date of issue of the Determination (see paragraphs 21 and 22 of Taxation Ruling TR 92/20).

1. The FI Cell is a specialist cell within the ATO. Its purpose is to provide a reference point and 'centre of expertise' to resolve the most complex and significant issues arising from the taxation of foreign income.

2. "Foreign Income" means matters relating to:

*
The Controlled Foreign Company measures
*
The Transferor Trust measures
*
The Foreign Investment Fund measures
*
The Foreign Tax Credit System

3. The objectives of the FI Cell are to:

(a)
Co-ordinate the identification and resolution of the more complex and significant foreign income issues.
(b)
Implement strategies which provide solutions to issues, ensuring that decisions and outcomes are widely communicated.
(c)
Provide a focus for, and promote the discussion and consideration of, the taxation of foreign income.

4. The Determinations and Rulings issued by the Cell provide a means of communicating the ATO view on foreign income matters.

Commissioner of Taxation
19 August 1993

References

ATO references:
NO FI Cell 163

ISSN 1038 - 8982

Subject References:
foreign income
specialist cell

TD 93/160 history
  Date: Version: Change:
You are here 19 August 1993 Original ruling  
  17 December 1997 Withdrawn  

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