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What the new CFC Amendments mean for Australians structuring their investments into the United States through LLCs.

Publication date: 01 Jun 08 | Source: ASIA-PACIFIC TAX BULLETIN

Issue: Vol 14 No 3 2008

Pages: pp.188-197

Abstract:
Structuring an overseas business investment raises questions on whether branches or separate entities should be established. Recent amendments to Australians investing into the United States via LLCs provide an opportunity for Australians to circumvent the US classical tax system and Australia's own CFC rules. After providing an overview of LLCs, this article will consider how the recent Australian tax amendments affect investments via LLCs. While welcomed, various problems are highlighted which may present problems for Australians utilising LLCs.

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Author profile

Dr Brett Freudenberg CTA
Photo of author, Brett FREUDENBERG Brett Freudenberg is an Associate Professor – Taxation at Griffith University (Australia). Brett is known for his research expertise in the tax law and policy issues facing private enterprises, as evidenced by his Fulbright Scholarship (2006) and over 50 refereed publications in leading Australian and international journals. Associate Professor Freudenberg’s research has analysed whether Australia should introduce a tax flow-through company (S Corporation), the tax treatment of discretionary trusts and the motivation for choice of business structure. Associate Professor Freudenberg’s research has informed government policy as he was invited to present his PhD research findings to the Australian Treasury as part of the Henry Tax Review. Brett is passionate about education being a transformative process, and his effectiveness as a teacher has been recognised through five national awards (including the award of two Australian Learning and Teaching Council citations: 2008 & 2011). - Current at 29 May 2017
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