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Foreign Income: Board of Taxation Position Paper, and De-quarantining and Foreign Tax Offset Provisions

Published on 07 May 2008 | Took place at RACV Club, Melbourne, VIC

The Board of Taxation's position paper on Australia's anti-tax-deferral regimes was released on 12 March 2008, and the de-quarantining rules for foreign losses and foreign tax offsets will become effective, for most taxpayers, on 1 July 2008. This event presented an opportunity to catch up with these developments and to identify issues ahead of the game.

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

Individual sessions

Foreign income: board of taxation position paper

Author(s):  Richard SHADDICK

This presentation includes a discussion of the recent review of the foreign source income anti-tax-deferral regimes by the Board of Taxation and in particular focusses on:

  • harmonisation: an abandoned ideal
  • active vs passive: a wobbly cornerstone
  • 27 positions: wheat and chaff
  • public companies: out of the frying pan
  • foreign trusts: 30 years of havoc.
Materials from this session:

Foreign income tax offsets, foreign losses and transitional rules

Author(s):  Brendan DARDIS

This presentation covers the new foreign tax offset rules and the removal of foreign loss quarantining. In particular, it focuses on:

  • operation of the new foreign tax offset rules
  • application to CFC's and FIF's
  • foreign tax credit carry forward
  • removal of foreign loss quarantining
  • conversion of existing losses.
Materials from this session: