Workshop one - Outbound investment paper

Member Price: $57.00

Non Member Price: $75.00

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 currently a Senior Associate at Greenwoods & Freehills. Cameron advises on a wide range of corporate tax matters, with a particular focus on mergers and acquisitions, demergers, capital management and employee share schemes.
Current at 06 February 2014
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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 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
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Author Photo - Jane Michie CTA
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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This was presented at 2011 Tax Specialist Workshop.

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

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

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

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