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International Tax Masterclass 2006

Published on 27 Sep 2006 | Took place at Tattersalls Club, Sydney, NSW

International tax reforms are continuing in Australia and the impact of more recent reforms is now coming to light. This seminar brought together leading international tax experts to provide their insights on the changes, the impacts and the current state of play with particular focus on the impacts on structuring of investments and financing.

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

Individual sessions

Structuring real estate investments into continental Europe

Author(s):  Matthijs VOGEL

This presentation and case study covers the following topics:

  • focus on investments by Australian property trusts in continental European real estate
  • overview of main continental European tax issues and their solutions
  • examples include Germany, the Netherlands, Luxembourg, France and Spain.
Materials from this session:

Recent international tax issues in treaties and other developments

Author(s):  Susan BLANCHE,  Robert DEUTSCH

This paper covers:

  • captive insurance companies
  • beneficial entitlement
  • treaties and capital gains for non-residents
  • McDermott's case
Materials from this session:

The Debt Equity Rules in Australia and Developments in Cross Border Financing Arrangements

Author(s):  Steven ECONOMIDES

This paper covers:

  • jurisdictional asymmetric funding transactions (JAFT) with New Zealand, UK and US
  • the connected entity test and JAFTs
  • interest / dividend withholding tax issues arising from JAFTs.
Materials from this session:

Key developments in taxation of expats and inpats

Author(s):  Rob BASKER

This paper covers:

  • temporary resident exceptions
  • CGT issues
  • ESAS changes
  • associated payroll / superannuation obligations.
Materials from this session:

Australian taxation of foreign hybrids - is it working?

Author(s):  John ALLEN

This paper covers:

  • compliance / FX issues
  • characterisation of particular entities as foreign hybrids
  • impact of interposed entities
  • interaction of foreign hybrids and Division 6C trusts.
Materials from this session:

Re-targeting capital gains tax for non-residents: Proposed Division 855 - "Winners and Losers"

Author(s):  Richard SHADDICK,  Ken SPENCE

The taxation of inbound investments into Australia stands to be dramatically altered by the proposed provisions of Division 855 that have recently been introduced into Parliament. This re-targeting of capital gains tax for non-residents will be beneficial for some non-residents but for others with investments in Australian “land-rich” entities, this will certainly not be the case.

This paper was also presented at the 'International Tax Masterclass' held in Sydney on 27 September 2006. 

Materials from this session: