The Australian Taxation Office released Interpretative Decision ATO ID 2008/80 in which it expressed a view that a limited partnership, formed under the Delaware Revised Uniform Limited Partnership Act (DRULPA) is a foreign hybrid limited partnership for the Australian taxation purposes, notwithstanding its legal status as a separate entity. Briefly, foreign limited partnerships may be classified as foreign hybrid partnerships, in which case they are treated, for the Australian taxation purposes, not as a CFC, but as a flow-through entity. One of the requirements for such a classification is that the foreign partnership must be a "limited partnership", as defined...