Australia's System for Relieving Foreign Source Income from Double Taxation: Yesterday, Today and Tomorrow

The following article has been written in two parts. The first part, dealing with the decision in Burton v Federal Commissioner of Taxation at first instance up to and including the author's analysis, was written prior to the Full Court delivering judgment on the taxpayer's appeal on 22 August 2019. The second part, dealing with the Full Court's dismissal of the taxpayer's appeal and the author's observations on their Honours' reasons, was written after that date. At the time of writing the second part, the author did not know whether the taxpayer intended to apply for special leave to appeal to the High Court of Australia.