Bifalgorithm post · Fuscalite · Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds did not violate a duty to cooperate with the vendor

ATO Determination

ATO Determination (Fuscalite · Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds…

Ideas in this flowchart

  • Post-closing residency certification efforts, disclosure, and withholding tax outcome
  • The Company sought residency certifications from members of the LLCs and LLPs.
  • The certification efforts achieved no significant success.
  • Toward the end of the 18-month period, the Company made a voluntary disclosure to the ATO.
  • The ATO found inadequate evidence of the residency status of the beneficial recipients of the deemed dividend.
  • Withholding tax was payable at the 30% rate.
  • The withholding tax was paid.
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ATO Determination

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Fuscalite

1 page

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USR292600b83e2a
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"After the closing, the Company sought, without significant success, to receive certifications from the members of the LLCs and LLPs as to their residency status. Towards the end of the 18-month period, the Company made a voluntary disclosure to the ATO. The ATO determined that, since there was inadequate evidence of the residency status of the beneficial recipients of the deemed dividend, withholding tax at the 30% rate was payable, which was then paid."

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