Published on 27 Oct 11
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers a CFC case study including:
- identifying the CFC and attributable taxpayers CFC
- tracing through CFCs
- calculating attributable income for Irish Lease Co, Lux Fin Co and Caymans Hold Co
- distributions paid to attributable taxpayer.
Cameron Blackwood ATI
Cameron Blackwood brings more than a decade of transactional tax expertise to his role as Director in Greenwoods & Herbert Smith Freehills’ Sydney office. He specialises in advising clients on the tax complexities of mergers, acquisitions and restructures, including cross-border issues and all aspects of employee share schemes; and regularly works in close collaboration with Herbert Smith Freehills. After joining the Greenwoods & Herbert Smith Freehills as a graduate in 2004, Cameron built his corporate experience advising companies and on a wide range of advisory and compliance matters, including a secondment with BHP Billiton. His industry knowledge is broad and includes the mining, real estate and financial services sectors. Current at 04 November 2016
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Lynnette Kelly CTA
Lynn is an Executive Manager at the Commonwealth Bank of Australia and leads the Bank's Advising tax team. Her focus spans both international and domestic tax issues. Prior to joining the Bank in 2005, Lynn worked as a Tax Manager at Fairfax and Thomas Cook after beginning her career at PricewaterhouseCoopers. Current at 26 February 2014
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Christian Holle ATI
Christian is a Partner with
PricewaterhouseCoopers Current at 01 February 2015
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Jane Michie CTA
Jane is an Executive Director at Macquarie Group in the Taxation Division. She specialises in income tax issues, particularly international tax and the taxation aspects of the financial services industry. Jane is heavily involved in the consultation process with Treasury on the proposed changes to the anti-deferral measures. Current at 10 November 2011
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