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CFC changes paper

Published on 22 Sep 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

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.

Author profile:

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 Click here to expand/collapse more articles by Neil BILLYARD.
 

This was presented at International Tax Masterclass.

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