Streaming Video Package

ondemand_video Session 10.5: Tax technology trusts and ethics video

This video covers tax technology trusts and ethics.

ondemand_video Session 5.4 How should professional practices be structured in the future? video

Professional practices are changing; technological disruption means work once produced through professional skill may soon be produced through capital investments such as Artificial Intelligence and machine learning. In some professions, annuity or subscription-based models are emerging and as the professions grapple with change, current approaches to the structuring of professional practices may need a rethink. This video considers these issues.

ondemand_video Session 4.4 What is the current framework for structuring professional practices? video

There are many varied approaches to structuring professional practices and these have arisen due to many influences. This video considers those influences and how they should apply in current circumstances.

ondemand_video Session 3.4 When is professional practice income alienable? video

This video examines what the case law says about when professional practice income can be alienated to entities other than the individual professional in light of current rules of practice and ethical guidelines. Issues that were considered include:

• the case law, from Peate through Galland to Gulland, Watson and Pincus and beyond
• what are the key features to look out for?
• does size matter and from what perspectives?
• how does Part IVA affect alienation of professional practice income?

ondemand_video Session 9.5: How does the change agenda impact the tax profession? video

Disruptive technologies are impacting the tax profession. The tax professional of the future will need to be cognisant of and embrace new technologies and ways of working. We are seeing significant changes in the tax compliance landscape - being driven by both the regulators and also technology providers. This video explored some of these developments and how they are impacting the profession. The future will belong to those that embrace the new but at the same time, focus on what cannot be disrupted - the human connection will become extraordinarily valuable.

ondemand_video Session 14.4: Practical tax issues for non-resident investors video

This video covers topical issues in foreign institutional investment in Australia, including:

• recent trends in relation to ATO involvement in FIRB applications
• issues associated with using unitholder/ shareholder debt, including the ATO’s flags
• structuring impacts of the recent changes in foreign investment, including whether a MIT should be used.

ondemand_video Session 13.4: Controlled foreign companies video

30 years and still counting!!! The proposed introduction of Australia's CFC rules was first announced on 12 April 1989. Despite a relatively settled period in the last decade, the Commissioner has recently introduced increased CFC disclosure requirements in the IDS. Is this a harbinger of future CFC reforms? Do the CFC rules need modernising to keep pace with foreign tax law reforms and the digital economy? Have taxpayers and tax advisers grown complacent? This video covers all of these questions and more as we look at the current state-of-play of the CFC rules.

ondemand_video Session 12.4: OECD anti-hybrid mismatch rules video

Australia has introduced the OECD hybrid mismatch rules to its domestic legislation, with many rules now in force. Although aimed at aggressive structuring by multinational corporations, the rules have an extremely broad application and apply to ordinary commercial transactions of minor amounts involving all kinds of entities. This video focuses on the application of the rules by reference to a number of examples that taxpayers are likely to commonly encounter in practice.

ondemand_video Session 19.2: Demergers – where are we now? video

This video considered the key tax issues associated with demergers in light of recent public transactions and ATO guidance.

ondemand_video Session 10.4: International tax structuring and cross-border financing video

If the only certain things in life are death and taxes; it could perhaps be said that the only certain thing in Australian tax is the ongoing evolution of the Commissioner's approach towards:

• cross-border financing transactions (including withholding taxes, guarantee fees, thin capitalisation, and interest free loans)
• international corporate restructures
• value chain structuring (including marketing hubs)
• perceived "BEPS" activity and structures.