Published on 01 Oct 05
by "THE TAX SPECIALIST" JOURNAL ARTICLE
The conduit foreign income rules are the last major piece of international tax reform aimed at eliminating Australian tax on foreign sourced income flowing through Australia where the ultimate owners are non-residents.
Neil Billyard CTA
Neil is a Partner in International Corporate Tax
at KPMG. Neil has over 22 years corporate tax experience and
specialises in foreign merger and acquisition activities of Australian
multi-nationals, cross-border funding, the repatriation of profits and
other related structuring. He is actively involved in working with
Treasury and government on a variety of international tax reform
issues, including assisting with policy development and drafting of
legislation. He has lectured the Master of Laws/Tax course at the
University of Sydney and is a regular presenter for The Tax Institute. Current at 01 February 2011
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Alison is a Tax Director at KPMG and has over 10 years corporate tax experience in advising both inbound and outbound clients on a range of international tax issues. During her career, Alison has specialised in advising on the controlled foreign company and foreign investment fund rules for outbound Australian multinationals, in addition to broader funding, holding and repatriation issues for a range of clients in the property, mining, manufacturing and services industries. Current at 31 March 2009
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