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New CGT exposures and exemptions for non-residents paper

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.

Author profiles:

Richard SHADDICK
Current at 12 October 2010 Click here to expand/collapse more articles by Richard SHADDICK.
 
Author Photo - Ken SPENCE
Ken SPENCE
Current at 21 May 2009 Click here to expand/collapse more articles by Ken SPENCE.

 

This was presented at Queensland State Convention: Reach for the Stars .

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