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TD 2022/9 - Income tax: is section 951A of the US Internal Revenue Code a provision of a law of a foreign country that corresponds to sections 456 or 457 of the Income Tax Assessment Act 1936 for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997 ?   flag 

[2022] ATOTD 9
Australian Taxation Office
Australia - Commonwealth

Legislation Cited

Legislation Name Provision
Treasury Laws Amendment (Tax Integrity and Other Measures No.2) Bill 2018 (Cth)
Taxation Laws Amendment (Foreign Income) Bill 1990 (Cth)
Income Tax Assessment Act 1936 (Cth) s456, s457
Income Tax Assessment Act 1997 (Cth) s10.5, s12.5
Taxation Administration Act 1953 (Cth)
Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Act 2018 (Cth)
Taxation Laws Amendment (Foreign Income Measures) Bill 1997 (Vic)

Cases and Articles Cited

Case Name Citation(s) Court Jurisdiction Date †  Full Text Citation Index
Treasury Laws Amendment (Tax Integrity and Other Measures No 2 Act 2018 United Kingdom circa 2018 flag 2
Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092; (2015) 102 ATR 13 Federal Court of Australia Australia - Commonwealth 23 Oct 2015 AustLII flag 22
Convention between the Government of Australia and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains [2003] ATS 22 Australia circa 2003 AustLII flag 21
Convention between the Government of Australia and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [1983] ATS 16 Australia circa 1983 AustLII flag 37
Winter v Ministry of Transport [1972] NZLR 539 New Zealand circa 1972 LexisNexis flag 16

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