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International Tax into the 21st Century

Published on 14 Jun 1996 | Took place at Mt Eliza, VIC

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Individual sessions

Cross border leasing - asymmetrical taxation treatment

Author(s):  Oliver YATES This paper introduces cross border leasing, then discusses:
- leesee's benefits
- transaction description
- taxation
- choice of jurisdiction.

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Concepts of Residence & Source into the 21st Century

Author(s):  The Hon. Justice Ian GZELL The concepts of residence and source are fundamental to the design of taxation structures. Theoretically a country can levy taxes on any person it chooses with respect to any economic activity or asset and wherever situated. But the pragmatic problems of enforcement with respect to subjects or objects of taxation beyond the borders of a country have led to the establishment of two basic principles which determine fiscal structures: the source principle and the residence principle.

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Outbound investment - listed countries

Author(s):  Tony CLEMENS This paper comments on the commercial and legislative environment in which Australian companies operate, particularly in relation to conducting business outside Australia in countries which are listed in Schedule 10 to the Income Tax Regulations.

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Outbound investments

Author(s):  Peter DIMECH,  David SCOTT This presentation covers:
- focus on global tax cost
- Australian investor profile
- foreign country aspects of doing business
- use of holding companies
- Australian tax issues.

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Foreign tax credits - past, present and future

Author(s):  Richard SHADDICK To this day, the foreign tax credit legislation has not received the attention it deserves. The object of this paper is, somewhat, to redress the balance.

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Inbound investments

Author(s):  Grant MILLARD This paper not so much seeks to address the basic issues in planning inbound investment but attempts to focus on current investment structures and various technical concerns with certain structures. This paper also seeks to project into the future by assessing taxation risks of various planning techniques and thereby lays a foundation for planning based on risk minimisation and current international trends.

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Developments in international tax law

Author(s):  Richard J VANN This paper considers a number of emerging issues in international tax law as a window on the future of international taxation. The discussion begins within tax treaties, looking at how they are coping with two increasingly important issues in international taxation - high value services and international tax administration. Then the discussion looks at tax treaties and international taxation from without - noting the growing influence of international trade and other instruments on taxation and the international institutions that are quietly shaping the international tax order in a way that moves tax sovereignty from the national to the international level.

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Dealing with dividend streams

Author(s):  Tony PANE This paper focusses on shareholders and, more particularly, dividend streams from a company to shareholders in different jurisdictions.

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ATO's approach to international tax into the future

Author(s):  Jim KILLALY It is reasonable to expect that the ATO will be reviewing how the various 'chunks' of the international tax regime are operating in practice and that it will draw any problems to the attention of policy makers. The ATO has been undertaking reviews based on overall trends, industry studies, tax return data and casework. This paper is a distillation of some of this research and experience.

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