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2004 Financial Services Taxation Conference: A Brave New World

Published on 18 Mar 2004 | Took place at Royal Pines Resort, Gold Coast, National

The program of this conference was structured to deal with many current tax issues facing financial services groups, including banking, funds management and life insurance.

It further explored most of the major tax reform issues affecting the financial services industry. 2003 has seen the enactment of further tranches of consolidation legislation, the first instalment of the long awaiting TOFA regime and the introduction of a bill containing the first tranche of the RITA changes. These seminar materials cover each of these.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Reform of Australia's International Taxation Arrangements

Author(s):  Alf CAPITO,  Emanuel HIOU This seminar paper covers the following:
- update on progress of the international tax reform agenda
- impact of Bills tabled so far on CFCs, dividend repatriation strategies and capital gains
- impact on corporate behaviour of remaining changes, including corporate structure issues
- are the reforms enough to satisfy MNEs?

Materials from this session:

Foreign Investment Funds and Capital Gains Tax

Author(s):  Andrew MILLS,  Rob WARD This seminar paper covers the following topics:
- the new exemption for super entities - a work in progress
- is the 10% a panacea?
- CGT exemptions for non-residents - three stages
- other changes - IWT exemption, new rental WHT and funds management
- general review of FIF - what's still to come.

Materials from this session:

Part IVA in Wonderland: The New Business Tax System

Author(s):  AH (Tony) SLATER This seminar paper covers the following topics:
- where is Part IVA heading?
- must a scheme still 'stand on its own feet'?
- how is purpose to be determined?
- what reliance can be placed on making elections?

Materials from this session:

Tax Aspects of Share Buybacks

Author(s):  Mark FERRIER A discussion of share buybacks with regard to capital streaming, franking credit streaming, buyback price, entitlement to franking credits and rulings and ATO attitudes.

This paper was also presented at the Financial Services Conference held on the Gold Coast on 18 March 2004.

Materials from this session:

Tax Preferred Asset Financing and Division 250

Author(s):  Steve FORD This case study covers the following topics:
- the exposure draft rules explained
- industry reaction / key submission issues
- financial impact - worked example
- latest developments.

Materials from this session:

Important Input Tax Recovery Issues

Author(s):  Ian JEFFREY This seminar paper covers the following topics:
- direct attribution
- apportionment methodologies
- reduced input tax credits
- interaction of input tax recovery with income tax.

Materials from this session:

State Tax Impediments to the Provision of Financial Services

Author(s):  Steven STEVENS This presentation covers the following topics:
- Uniform Life Insurance Model proposals
- Life Riders - General or Life Insurance?
- New South Wales Land Rich Changes - implications for managed fund and property trusts
- Trust Mergers.

Materials from this session:

Product Rationalisation

Author(s):  Michael BROWN This seminar paper covers the following topics:
- why rationalisation of financial products is an imperative for the industry
- the shared objectives of the product providers, customers and regulators
- the obstacles to product rationalisation - tax and other considerations
- the solution and what we need to do to achieve it.

Materials from this session:

Developments in Life Insurance

Author(s):  Jeremy HIRSCHHORN,  Shez KURUKULASURIYA This seminar paper covers the following topics:
- practical implications of the Division 320 technical amendments
- identifying and managing life insurance company issues under a consolidation regime
- implications of tax reform for product development and rationalisation
- unresolved issues for life insurance companies.

Materials from this session:

Taxation of Financial Arrangements

Author(s):  Neil WARD We are slowly progressing through the reform of Taxation of Financial Arrangements. This seminar paper covers particular issues arising from the reform to date and a view of what more should we expect, specifically:
- foreign exchange
- traditional securities
- debt/equity developments
- taxation of specific financial products - swaps, forwards, options etc.

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Transfer pricing issues in a financial services organisation

Author(s):  Damian PRESHAW,  Paul BALKUS This seminar paper covers the following topics:
- intellectual property in a Financial Services organisation: What is it? How do you price it?
- is a CCA an appropriate pricing method? If so, when?
- case study to illustrate the transfer pricing and related income and withholding tax issues.

Materials from this session:

ATO Approach to Compliance

Author(s):  Ashley KING This presentation covers the following topics:
- what attracts ATO attention?
- risk assessment
- audit process, plans and protocols
- current compliance issues.

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ATO Audits

Author(s):  Toby KNIGHT This seminar paper covers the following topics:
- managing the audit process: communication and information flow with the ATO; and audit plans and protocols
- identification of issues and exposures
- ATO access powers
- answering information requests
- ATO interviews
- legal professional privilege and access guidelines - some pitfalls
- positioning for negotiation and/or litigation.

Materials from this session:

Managing the Consolidations Process

Author(s):  Liz TROMANS,  Sonia MORRIS This presentation covers the following topics:
- what's necessary before you can consolidate?
- post consolidation issues: making and funding payments, ATO liaison, dealing with disputes
- accounting implications
- technical issues: single entity, acquisitions and dispositions.

Materials from this session:

Superannuation Update

Author(s):  Stephen ROBERTS This presentation covers the following topics:
- impact of FSR
- outsourcing
- strategies for a low return environment
- defined benefit deficits.

Materials from this session: