Published on 22 Jul 2003
| Took place at Radisson Plaza Hotel, Sydney
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.
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
- narrowing of tainted services income
- the dividend and CGT exemptions
- what the changes mean for tax effective restructuring and
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?
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.
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.
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.
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
-- administrative assistance
- Tax treaty process:
-- negotiation priorities
-- most favoured nation clauses
-- parliamentary approval of treaties.