Let’s get active! The CGT participation exemption

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Publication date: 01 Oct 06

Source: "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

Abstract:
The CGT Participation Exemption reduces capital gains and losses of an Australian resident holding company on sale of shares in a foreign company conducting an “active” business. This article examines the exemption and, in particular, the tax issues concerning whether assets of a foreign company are “active” in nature.

Author profile:

Dr Philip Bender
Philip Barrister at Law, Victorian Bar has many years experience in advising on international tax, including structuring of managed funds and other inbound and outbound investments. Philip advises and appears regularly for taxpayers and the Commissioner in both the AAT and Federal Court, including on international tax matters. He also appears in commercial and trust matters in State Courts. Philip is also a contributing author to 2 books (Taxation of Financial Arrangements and Business Tax Reform in Prospect and Retrospect) and has published numerous articles on international tax issues.
Current at 26 August 2011
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