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International Masterclass

Published on 22 Jul 2003 | Took place at Radisson Plaza Hotel, Sydney, NSW

International Tax has become the latest area of reform and significant changes have been announced by the government. This year's Masterclass involved leading practitioners from private practice, commerce, the bar and academia who provided unique insights into the changes.

You don't need to have offshore investments to be affected by many of these latest changes. These seminar materials will benefit all tax specialists who need to analyse any transactions with an international flavour.

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

Individual sessions

Proposed Reform of the Controlled Foreign Company Measures

Author(s):  Zorach DISKIN This seminar paper covers the following topics:
- overview and timing of the Budget proposals
- broadening the carve-out for the broad-exemption listed countries
- narrowing of tainted services income
- the dividend and CGT exemptions
- what the changes mean for tax effective restructuring and capital flows.

Materials from this session:

Offshore Portfolio Investment

Author(s):  Michael BROWN This seminar paper covers the following issues:
- why is the balanced portfolio exemption the focus of foreign investment fund (FIF) reform?
- why are superannuation entities getting a carve out from FIF?
- the FIF exemption for funds management activities
- Australia as a global centre for funds management
- should we now be using different structures?

Materials from this session:

Outward Investments

Author(s):  Alf CAPITO This presentation covers the following issues:
- issues for outbound investors
- dividend exemption
- CGT exemption
- review of corporate structures
- likely exposures/opportunities.

Materials from this session:

The New Foreign Resident Withholding Regime

Author(s):  Christopher CATT This seminar paper covers the following issues:
- extension of PAYG withholding from 1 July 2003
- likely taxable payments made to non-residents
- exemptions, treaty relief and seeking tax refunds
- gross-up clauses in services agreements
- dealings between non-residents
- update on royalty, dividend and interest withholding taxes.

Materials from this session:

Foreign Hybrids.

Author(s):  Neil BILLYARD

Whilst limited partnerships and limited liability companies have become the vehicle of choice for investing into many countries, Australian tax law has provided a significant risk of global double taxation. Thankfully, the law is to be clarified to eliminate this possibility.

This was also presented at the International Masterclass held in Sydney on 22 July 2003.

Materials from this session:

Foreign Currency Gains and Losses - a whole new regime

Author(s):  Tony FROST This seminar paper covers the following topics:
- affected transactions and taxpayers
- revenue/capital characterisation and timing rules
- functional currency regime
- transitional and grandfathering arrangements
- other FX and TOFA measures still to come.

Materials from this session:

Australia's New Treaty Policy: Noise or Music?

Author(s):  Richard J VANN This seminar paper covers the following issue:

- Tax treaties:
-- shift from source to residence
-- definition of permanent establishment
-- international shipping and air transport
-- dividends and interest
-- royalties and high value services
-- capital gains
-- sourcing rule
-- non-discrimination
-- administrative assistance

- Tax treaty process:
-- negotiation priorities
-- most favoured nation clauses
-- consultation
-- parliamentary approval of treaties.

Materials from this session: