Acting U.S. Treasury Deputy Assistant Secretary (International Tax Affairs), Scott Levine, has sent a letter dated 5 April 2024 to the Australian Treasury First Assistant Secretary, Marty Robinson, highlighting issues with certain conclusions regarding the taxation of software royalties in the new Draft Taxation Ruling TR 2024/D1 Income tax: royalties - character of payments in respect of software and intellectual property rights and the implications for the U.S.-Australia tax treaty. --- Dear Mr. Robinson: I am writing regarding Draft Taxation Ruling TR2024/D1, which was issued by the Australian Tax Office (the "ATO") for public comment earlier this year. TR2024/D1 is...