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International tax strategies/structuring for SMEs presentation
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 presentation 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.
Author profile
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 21 August 2012
This was presented at 48th Victorian State Convention .
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Individual sessions
Current issues in self managed superannuation
Author(s): Heather GRAYMaterials from this session:
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Capital allowances-Opportunities now arising
Author(s): Andrew WOOLLARDMaterials from this session:
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Tax consolidation-Continual evolution
Author(s): Richard BUCHANANMaterials from this session:
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Managing trust losses
Author(s): Meagan O'CONNOR, Rob JEREMIAHMaterials from this session:
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Tax risk management in a changing world
Author(s): Tony FULTONMaterials from this session:
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Division 7A the 'sleeping giant'
Author(s): David STAVROPOULOSMaterials from this session:
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Tax accounting - a changing landscape: what it means for you
Author(s): Ronen VEXLER, David ROMANS, Michelle Thomas, David MorrinMaterials from this session:
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International tax strategies/structuring for SMEs
Author(s): James NewnhamMaterials from this session:
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Tax in recessionary times
Author(s): Mark POOLEMaterials from this session:
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Bamford v Federal Commissioner of Taxation
Author(s): Terry MURPHYMaterials from this session:
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The new Tax Agents Services Regime - Setting up the procedures necessary to comply with your obligations
Author(s): Sue WILLIAMSONMaterials from this session:
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Structuring and financing investments into Asia
Author(s): Dino FARRONATOMaterials from this session:
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Trusts and distribution resolutions in the light of Bamford
Author(s): Nabil (Bill) F. OROWMaterials from this session:
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Transfer pricing - the practicalities of achieving an arm's length outcome
Author(s): Keir CORNISHMaterials from this session:
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Promoter penalties
Author(s): Stephanie MARTINMaterials from this session:
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Tax controversy strategies - preparing for ATO reviews, audits and tax disputes
Author(s): Peter POULOSMaterials from this session:
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Merger and acquisition outbound
Author(s): John BRAZZALEMaterials from this session:
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Professional practices - State of play
Author(s): Mark NORTHEASTMaterials from this session:
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Practical TOFA Considerations for corporates
Author(s): Neil WARDMaterials from this session:
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Practical transfer pricing documentation for the SME market
Author(s): Shannon SMITMaterials from this session:
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GST Today – Cases update, legislative update & rulings update
Author(s): Geoff MANN, Suzanne KNEEN, Michelle SIUMaterials from this session:
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Hybrid financial instruments: Classifying hybrid instruments under the Debt/Equity Rules and related issues
Author(s): Cameron RIDER, Martin FRYMaterials from this session:
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Inbound investment emerging issues
Author(s): Vik KHANNAMaterials from this session:
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Case-law developments in Section 8-1
Author(s): Michael CLOUGH, Ged O’SHAUGHNESSYMaterials from this session:
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Tax controversy strategies (preparing for ATO reviews, audits and disputes)
Author(s): Peter POULOSMaterials from this session:
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Demerger case study
Author(s): John BRAZZALEMaterials from this session:
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