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Workshop one - Outbound investment paper

Publication date: 27 Oct 11

Source: NATIONAL DIVISION, THE TAX INSTITUTE

Abstract:

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.

Author profiles:

Cameron Blackwood ATI
Cameron is a Senior Associate at Greenwoods & Freehills, a specialist tax advisory practice. He advises on a wide range of corporate tax matters, with a particular focus on mergers and acquisitions, banking and finance, funds management and employee share schemes. More recently, Cameron has been involved in the consultation process with Treasury on the reform of the anti-deferral measures.
Current at 10 November 2011
Click here to expand/collapse more articles by Cameron BLACKWOOD.
 
Lynnette Kelly CTA
Lynn is an Executive Manager within the Commonwealth Bank of Australia's 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 10 November 2011
Click here to expand/collapse more articles by Lynn Kelly.

Christian Holle ATI
Christian joined the International Tax Services Group in 2001 after five and a half years in the Corporate Tax/Financial Services Area of PricewaterhouseCoopers in Sydney. He is specialised in merger & acquisition advice as well as cross border tax and finance issues, and has advised Australian and offshore clients on various acquisitions overseas and in Australia with regard to tax structuring, due diligence and financing.
Current at 10 November 2011
Click here to expand/collapse more articles by Christian HOLLE.

 

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Purchase individual materials from this event:

Workhop one - Outbound investment
Author(s):  Jane MICHIE,  Cameron BLACKWOOD,  Christian HOLLE,  Lynn Kelly

Workshop two - M&A transactions - Seller's perspective
Author(s):  David MARSCHKE,  Hayden BENTLEY,  Michael HENNESSEY,  Denise HONEY

Workshop 4 - Intellectual property
Author(s):  Peter FEROS,  Eddy MOUSSA,  Tracey RENS,  Robert Zalud