Published on 15 Jun 04
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper looks at possible ownership structures that can be set up to maximise the flexibility for income redistribution within corporate groups. How should a business handle the many trade-offs - for example in trusts, the trade-off between flexibility and loss quarantining.
Part of this paper looks at the enactment of the so-called simplified imputation system which changed the position of companies - they now become both users as well as transmitters of franking credits. This paper looks at how the imputation system affects the ability of companies to pass income through chains of companies and other vehicles. It focusses especially on the recent amendments and new rules about losses arising from unusable franking credits.
Yan has 20 years’ corporate and international tax experience with a number of Big Four and Mid-Tier International Chartered Accounting firms. Yan is a Chartered Accountant and qualified lawyer. Yan delivers strong client service and commercially focused taxation advice to his clients particularly in the Food and Beverage and Professional Services sectors. He provides a versatile set of skills and experience in international tax/cross border tax advice, tax compliance and tax transaction/due diligence services. He is particularly experienced in leading teams consisting of international or indirect tax/transfer pricing specialists to provide comprehensive tax solutions to multinational client groups.
- Current at
06 October 2015