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Tax Losses/Foreign Income Tax Offset and Losses Regime

Published on 25 Jun 2009 | Took place at City West Receptions, Perth, WA

Now that Australia has joined the rest of the world in recession, losses are becoming an increasing reality for many taxpayers. With our clients' ever increasing ties offshore we as practitioners need to be abreast of the rules relating to domestic losses, together with the new Foreign Income Tax Offset and Losses Regime.

This event revisited the two threshold tests for recouping prior period domestic losses and updated them for recent developments, whilst also looking at maximizing the benefits and managing the risks from 1 July 2008 relating to foreign taxes and foreign losses.

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

Individual sessions

Foreign income tax offset and foreign loss rules

Author(s):  Mathew CHAMBERLAIN

This presentation covers:

  • an outline of the new rules & other changes
  • the abolition of foreign loss and foreign tax credit quarantining
  • the inclusion of a de minimis cap
  • issues for individuals, companies & superannuation funds
  • foreign income and credits flowing through trusts.
Note: When giving this presentation, the speaker referred to a related paper delivered at the 2008 WA State Convention: "Foreign Tax Offset Regime" by Andrew Mills.
Materials from this session:

Tax losses – Non-commercial losses, COT & SBT

Author(s):  Shirley GODFREY

This presentation covers:

  • Continuity of Ownership test (COT), practical points in applying the test, including amended tracing rules for widely held companies
  • same business test, including consideration of recent cases
  • non-commercial losses, including recently proposed budget amendments.
Materials from this session: