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Australian Federal Court Holds Only 50% Credit for U.S. Tax Paid on Gain that is Only 50% Taxable in Australia

|Approved Changes|Australia
Australia

A 22 August 2019 judgment of Australia's full Federal Court has been published regarding whether a full foreign tax credit may be claimed in respect of income only partially taxable in Australia. The case involved an Australian trustee of an Australian discretionary trust that held rights to interests in U.S. oil and gas wells. During the years 2010 to 2012, these rights were sold off, and bec…

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