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International Tax Masterclass

Published on 22 Sep 2010 | Took place at Hilton, Sydney, NSW

This event brought together leading international tax experts to review the most recent reforms and developments, providing you with practical insights and examining how the changes will impact on you.

Topics included:

  • changes to the CFC Regime
  • the operation of Australia’s conduit foreign income rules
  • what is happening to the space in which the FIF regime operated?
  • what tax issues have caused many foreign investors to give up, or hold off, directly investing in Australian securities, and what is being done to fix them?
  • recent developments in transfer pricing
  • taxation of business profits and the 2010 updates to the OECD model treaty
  • the impact on the FBT net caused by the changes to s23AG
  • international aspects of the operation of the new Division 83A
  • private equity inflows into Australia.

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

Individual sessions

CFC changes

Author(s):  Neil BILLYARD This paper covers:

  • release of the Treasury's second consultation paper on reform of the CFC rules
  • policy objectives and drafting approach
  • definition of CFC -accounting concepts of control
  • prima facie passive income
  • the ‘active business income' exemption
  • application of the integrity rule (part 30)
  • interaction of participation interests and the dividend exemption.
Materials from this session:

The operation of Australia’s conduit foreign income regime

Author(s):  Matt BUDGE,  Sue-Ann KHOO This paper covers:

  • underlying policy of the CFI regime
  • overview of the CFI rules
  • simple practical example
  • potential traps.
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The attribution landscape in a post FIF world

Author(s):  Taylor BLACK This paper covers the attribution in a post FIF world.

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Foreign investment in Australian securities

Author(s):  John KING This paper covers:

  • what is the continuing relevance of the capital/income distinction?
  • how do our source rules apply to the typical range of investments?
  • what has been the administrative practice of the ATO to date?
  • what is the relevance of FIN 48?
  • why do we need an investment manager regime (IMR)?
  • proposals for reform (I): introduce statutory exception to common law souce rules
  • proposals for reform (II): introduce a IMR.
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An update on transfer pricing issues

Author(s):  Bob DEUTSCH This paper covers an update on transfer pricing issues.

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OECD 2010

Author(s):  Richard J VANN This paper covers tax treaties and the 2010 OECD update: the new Article 7.

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New ESS provisions & cross border employees

Author(s):  Stephen COAKLEY This presentation covers new ESS provisions and cross border employees.

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The unintended FBT consequences of changes to s23AG

Author(s):  Elizma BOLT This paper covers:

  • s23AG - what has changed?
  • fringe benefits tax overview
  • the FBT ramifications
  • pitfalls for employers
  • practical solutions to manage FBT compliance for offshore employees.
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International tax rules and private equity developments

Author(s):  Chris GIBBS This presentation covers international tax rules and private equity developments.

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