There is no withholding tax on share transactions for CDIs. Dividends on the other hand are paid from the US where the withholding tax applies to the payment . The double tax treaty means the withholding tax deducted from those dividends are claimed as a tax credit in your Australian tax return. So in effect no tax is paid other than any Australian tax you are liable for on that dividend. Capital profits and losses on share transactions are dealt with in your Aust tax return.
Quarterly Earning Out in US, page-31
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