Published on 17 Mar 07
by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA
The Government has introduced new provisions to first narrow the focus of CGT for non-residents to Australian real property and permanent establishment assets and secondly introduce a rigorous “land rich” type mechanism that looks through interposed entities. This paper considers:
- which taxpayers will benefit?
- how this particular “land-rich” tracing mechanism operates
- structuring implications
- tax treaty interactions, i.e. whether Australia has the right to impose this new tax impost
- assets held through trusts.
This paper was also presented on 3 August 2007 by Ken Spence at the Queensland State Convention in Surfers Paradise.
Current at 12 October 2010
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