Published on 08 Oct 09
by VICTORIAN DIVISION, THE TAX INSTITUTE
The rules for structuring inbound and outbound investment for SMEs continue to change. This paper deals with the key international tax issues encountered by SMEs including:
- how to determine the right structure both here and there including:
- entry financing issues
- repatriation issues and your global tax rate
- branch vs company
- branch profit exemption
- foreign tax offsets - Division 770
- the impact of a bear market
- exit issues and Division 768-G.
James Newnham CTA
James Newnham, CTA is a Partner in DLA Piper's Tax Team with over 16 years' experience consulting to leading Australian companies and multinational groups. He provides practical direct tax advice with consideration to his clients specific business needs. James' tax structuring experience stems from advising on various transactions including mergers, demergers, capital restructures, IPOs, private equity acquisitions, share buy-backs, and cross-border expansions. He works with emerging and mature technology clients who have specific industry based tax issues. His areas of experience include drafting the tax aspects of legal documents, tax consolidation, international tax, capital gains tax, the debt/equity rules, debt forgiveness rules, and the employee share schemes. Current at 09 May 2016
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