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RCF IV: Limited partnerships, unlimited implications? paper


This paper covers:

  • RCF IV: background facts
  • limited partnerships & statutory construction
  • possible implications outside of tax treaties
  • tax treatment of ordinary income gain/business profits article
  • treatment of gain under Article 13/Division 855.

Author profiles

Gareth Redenbach CTA
Gareth is a barrister practising in revenue law and has over 15 years of experience in tax matters. He has advocated in all trial divisions in Victoria as well as in the High Court, Full Federal Court and Victorian Court of Appeal. He has appeared for both taxpayers and the Commissioner and including for the successful taxpayer in the Full Federal Court decision on taxation of trusts in Lewski v Commissioner of Taxation (2017) 254 FCR 145 and for the successful Commissioner in the first domicile case decided post-Harding (Handsley v Commissioner of Taxation [2019] AATA 917). Prior to joining the bar, Gareth was in-house counsel for the Macquarie Group based in New York responsible for managing transfer pricing and international tax matters across the Americas region. Gareth was previously a Senior Associate at Minter Ellison focussed on tax controversy and began his career in the international tax department of PwC. Gareth is a Senior Fellow at the University of Melbourne teaching in their LLM program and also teaches in the Victorian Bar’s Readers’ Course on taxation matters. Gareth is the former Chair of the Corporate Section and Executive Committee member of the US Committee of Banking Institutions on Taxation. Gareth also regularly participates and speaks at TIA, OECD, IFA and other conferences. - Current at 16 June 2022
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James Strong
James Strong is a Partner in the Corporate Tax practice of PwC with over 14 years professional experience. James leads the firm’s Energy and Mining Tax practice and works extensively with resource companies both in Australia and internationally. James is heavily involved in supporting companies with the implementation of the MRRT and expanded PRRT and is a member of the ATO NTLG Resource Rent Tax Sub-committee (representing the ICAA). - Current at 09 November 2012
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This was presented at VIC 6th Annual Tax Forum .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Tax issues with cryptocurrencies

Author(s):  Gareth Redenbach

Materials from this session:

Transfer pricing v the diverted profits tax – Too much overlap to be safe!

Author(s):  Damian PRESHAW

Materials from this session:

Legislative reforms in the property sector

Author(s):  Robyn Jacobson,  James Christodoulakis

Materials from this session:

RCF IV: Limited partnerships, unlimited implications?

Author(s):  Gareth Redenbach,  James STRONG

Materials from this session:

Private business: What’s attracting the Commissioner’s attention?

Author(s):  Anna Longley

Materials from this session:

Further details about this event:


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