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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     37

Cases Referring to this Case

Case Name	Citation(s)	Court	Jurisdiction	Date †	Full Text		Citation Index
TR 2024/D1 - Income tax: royalties - character of payments in respect of software and intellectual property rights	[2024] ATODTR TR2024/D1	Australian Taxation Office	Australia - Commonwealth	circa 2024	AustLII
TR 2024/D1 - Income tax: royalties - character of payments in respect of software and intellectual property rights	[2024] ATODTR 1	Australian Taxation Office	Australia - Commonwealth	circa 2024	AustLII
Ziolkowski and Commissioner of Taxation	[2023] AATA 292	Administrative Appeals Tribunal	Australia	2 Mar 2023	AustLII		1
PR 2023/16 - CHESS depositary interests over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust	[2023] ATOPR PR2023/16	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2023	AustLII
PR 2023/16 - CHESS depositary interests over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust	[2023] ATOPR 16	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2023	AustLII
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 ?	[2022] ATOTD 9	Australian Taxation Office	Australia - Commonwealth	circa 2022	AustLII
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 ?	[2022] ATOTD TD2022/9	Australian Taxation Office	Australia - Commonwealth	circa 2022	AustLII
N & M Martin Holdings Pty Ltd v Commissioner of Taxation	[2020] FCA 1186	Federal Court of Australia	Australia - Commonwealth	18 Aug 2020	AustLII		9
PR 2020/10 - Income tax: taxation consequences of investing in CDIs over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust - 2020	[2020] ATOPR 10	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2020	AustLII
TR 2020/5 - Income tax: application of section 6CA of the Income Tax Assessment Act 1936 and Australia's tax treaties and the payer's withholding obligations	[2020] ATOTR TR2020/5	Australian Taxation Office	Australia - Commonwealth	circa 2020	AustLII
TR 2020/5 - Income tax: application of section 6CA of the Income Tax Assessment Act 1936 and Australia's tax treaties and the payer's withholding obligations	[2020] ATOTR 5	Australian Taxation Office	Australia - Commonwealth	circa 2020	AustLII
PR 2020/10 - Income tax: taxation consequences of investing in CDIs over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust - 2020	[2020] ATOPR PR2020/10	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2020	AustLII
Burton v Commissioner of Taxation	[2019] FCAFC 141; (2019) 271 FCR 548	Federal Court of Australia	Australia - Commonwealth	22 Aug 2019	AustLII		4
FCT v Resource Capital Fund IV LP	[2019] FCAFC 51; (2019) 266 FCR 1	Federal Court of Australia	Australia - Commonwealth	2 Apr 2019	AustLII		9
PR 2017/7 - Income tax: taxation consequences of investing in CDIs over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust	[2017] ATOPR PR2017/7	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2017	AustLII
PR 2017/7 - Income tax: taxation consequences of investing in CDIs over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust	[2017] ATOPR 7	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2017	AustLII
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		22
TR 2014/3 - Income tax: satisfying the 'carrying on a business at or through a permanent establishment' requirement in section 23AH of the Income Tax Assessment Act 1936 where a Co is taken to have a permanent establishment (PE) in relation to substantial equipment	[2014] ATOTR 3	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TR 2014/2 - Income tax: the application of the ships and aircraft article of Australia's tax treaties to taxable income derived under section 129 of the Income Tax Assessment Act 1936 by a non-resident shipowner or charterer	[2014] ATOTR 2	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
PR 2014/17 - Income tax: tax consequences of investing in CDIs over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust	[2014] ATOPR PR2014/17	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2014	AustLII
TR 2014/3 - Income tax: satisfying the 'carrying on a business at or through a permanent establishment' requirement in section 23AH of the Income Tax Assessment Act 1936 where a Co is taken to have a permanent establishment (PE) in relation to substantial equipment	[2014] ATOTR TR2014/3	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
TR 2014/2 - Income tax: the application of the ships and aircraft article of Australia's tax treaties to taxable income derived under section 129 of the Income Tax Assessment Act 1936 by a non-resident shipowner or charterer	[2014] ATOTR TR2014/2	Australian Taxation Office	Australia - Commonwealth	circa 2014	AustLII
PR 2014/17 - Income tax: tax consequences of investing in CDIs over interests in the SPD R[R ] S & P 50 0[R ] ETF Trust	[2014] ATOPR 17	Australian Taxation Office Product Rulings	Australia - Commonwealth	circa 2014	AustLII
TR 2012/3 - Income tax: taxation of financial arrangements - application of subsections 230-30(2) and 230-30(3) of the Income Tax Assessment Act 1997 to gains and losses relating to exempt income or non-assessable non-exempt income	[2012] ATOTR TR2012/3	Australian Taxation Office	Australia - Commonwealth	circa 2012	AustLII
TR 2012/3 - Income tax: taxation of financial arrangements - application of subsections 230-30(2) and 230-30(3) of the Income Tax Assessment Act 1997 to gains and losses relating to exempt income or non-assessable non-exempt income	[2012] ATOTR 3	Australian Taxation Office	Australia - Commonwealth	circa 2012	AustLII
TR 2009/6 - Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities	[2009] ATOTR 6	Australian Taxation Office	Australia - Commonwealth	circa 2009	AustLII
TR 2009/6 - Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities	[2009] ATOTR TR2009/6	Australian Taxation Office	Australia - Commonwealth	circa 2009	AustLII
Deutsche Asia Pacific Finance Inc v FCT (No 2)	[2008] FCA 1570; 172 FCR 336; 73 ATR 1	Federal Court of Australia	Australia - Commonwealth	22 Oct 2008	AustLII		1
GE Capital Finance Pty Ltd v FCT	[2007] FCA 558; (2007) 159 FCR 473; (2007) 66 ATR 447	Federal Court of Australia	Australia - Commonwealth	19 Apr 2007	AustLII		9
TR 2005/5 - Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia	[2005] ATOTR 5	Australian Taxation Office	Australia - Commonwealth	circa 2005	AustLII
TR 2005/5 - Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia	[2005] ATOTR TR2005/5	Australian Taxation Office	Australia - Commonwealth	circa 2005	AustLII
Treaty Notes	[2003] ATS 14		Australia	circa 2003	AustLII		6
TR 2001/13 - Income tax: Interpreting Australia's Double Tax Agreements	[2001] ATOTR 13	Australian Taxation Office	Australia - Commonwealth	circa 2001	AustLII
TR 2001/13 - Income tax: Interpreting Australia's Double Tax Agreements	[2001] ATOTR TR2001/13	Australian Taxation Office	Australia - Commonwealth	circa 2001	AustLII
Treaty Notes	[2001] ATS 1		Australia	circa 2001	AustLII		1

Law Journal Articles Referring to this Case

Journal Article Title	Citation(s)	Author	Jurisdiction	Date †	Full Text		Citation Index
"An Old Tax is a Simple Tax: A Back to the Future Suggestion for the Simplification of Australian Corporate-Shareholder Taxation"	[2006] JlATaxTA 4	Taylor, C John	Australia	circa 2006	AustLII
"Australian Treaty Action 2001"	(2002) 22 Australian Year Book of International Law 381	Editors	Australia	circa 2002	AustLII