Published on 01 Oct 06
by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
The CGT Participation Exemption reduces capital gains and losses of an Australian resident holding company on sale of shares in a foreign company conducting an “active” business. This article examines the exemption and, in particular, the tax issues concerning whether assets of a foreign company are “active” in nature.
Philip is a Barrister and member of the Institute of Chartered Accountants practising in State and Federal taxation, superannuation and commercial law. He is also a sessional member of the Victorian Civil and Administrative Tribunal (although he still appears as a barrister in the tax list of that Tribunal). Philip advises and appears for taxpayers and revenue authorities in State and Federal courts and tribunals and has appeared on a number of occasions in the High Court. He has also been briefed by other government agencies including ASIC, the Official Trustee in Bankruptcy and the Victorian Government Solicitor's Office.
- Current at
01 September 2011