TOFA–The international dimension paper

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Non Member Price: $75.00

Publication date: 13 Feb 09

Source: NATIONAL DIVISION, THE TAX INSTITUTE

Abstract:

This paper examines:

  • the application of TOFA to cross border financial transactions
  • how TOFA affects foreign banks, internal transactions of banks and OBUs
  • interaction with the rules on forex gains/losses, withholding tax and CFC/FIF regimes
  • change of residence by companies and individuals.

Author profile:

Anthony Frost CTA
Tony is the Managing Director of Greenwoods & Freehills. With more than 25 years experience in tax, Tony has a focus on financial services and financial transactions. Tony has advised clients on a wide range of tax matters, including innovative financial products, mergers and acquisitions, cross-border dealings, transfer pricing, tax audits and negotiations with the Australian Taxation Office. Tony has also advised clients on various OBU matters over many years, and is part of the consultation group set up by Treasury to discuss changes to the OBU rules announced in the previous government’s 2013-14 Budget.
Current at 18 October 2013
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This was presented at Financial Services Taxation Conference 2009.

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