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Foreign entities – Characterisation and treatment for Australian tax purposes paper

Published on 18 Sep 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This is a continuing area of uncertainty as new foreign entities emerge. This paper covers:

  • characterisation of foreign entities: Partnership vs. Company
  • foreign hybrids - recent hot topics
  • OECD guidance regarding fiscally transparent entities (FTE's)
  • recent double tax treaty treatments of FTE's
  • case studies to illustrate the issues.

Author profiles:

David WATKINS
David is an International Tax Partner at Deloitte. David has over 20 years experience in corporate and international tax, including as a partner with Big 4 firms and a leading law firm. He has spent a number of years working in Malaysia and Singapore. David is a member of the ICAA International Tax Committee, has been a member of ATO / Treasury consultation committees and has appeared before Senate Committees on international tax matters. His experience includes a wide range of inbound and outbound structures with a focus on CGT, double tax agreements and foreign hybrids. His work has also included domestic and international tax issues associated with private equity and venture capital.
Current at 18 September 2008 Current at 27 April 2009 Click here to expand/collapse more articles by David WATKINS.
 
Alison RODI
Current at 15 June 2009 Click here to expand/collapse more articles by Alison RODI.

 

This was presented at International Tax Masterclass .

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

Individual sessions

Sharp edges in a modular world

Author(s):  Ian STANLEY

Materials from this session:



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