Published on 17 Sep 09
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper considers income tax developments in respect of inbound property investment structuring, including:
- the use of managed investment trusts (‘MITs')
- the interaction of Division 855 and the MIT withholding tax regime
- the particular issues for sovereign wealth funds and foreign pension funds
- withholding taxes, particularly interest withholding tax issues for leveraged structures
- the interaction of the Australian tax regime with investor home tax rules.
Joe Galea is a tax Partner at Deloitte Touche Tohmatsu with over 15 years of corporate tax experience advising clients across a range of industries, with a particular focus on property related entities. Joe has provided a range of income tax advice to property related entities, including tax consolidation, syndications and the structuring of acquisitions and disposals.
Current at 10 April 2006 Current at 13 October 2009
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