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Inbound investment - Application of Division 855 paper

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Published on 30 Aug 12 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers the following regarding inbound investment:

  • In what circumstances will I be subject to Australian CGT?
  • When should I use an Australian company versus foreign acquisition company?
  • Debt funding – when is it relevant?
  • What is the impact of the decision in TEC Desert?
  • Does functional currency matter?
  • If I use a foreign company, can I dispose my investment to an Australian purchaser?
  • Are there are any roll-overs available?
  • What happens with branch assets?

Author profiles

Melanie Cameron
Melanie Cameron is a Senior Manager at PricewaterhouseCoopers. - Current at 11 September 2012
James Strong ATI
James Strong is a Partner in the Corporate Tax practice of PwC with over 14 years professional experience. James leads the firm’s Energy and Mining Tax practice and works extensively with resource companies both in Australia and internationally. James is heavily involved in supporting companies with the implementation of the MRRT and expanded PRRT and is a member of the ATO NTLG Resource Rent Tax Sub-committee (representing the ICAA). - Current at 09 May 2017
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This was presented at International Tax Masterclass .

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Individual sessions

Inbound investment - Application of Division 855

Author(s):  James STRONG,  Melanie Cameron

Materials from this session:

Outbound investment - Exit strategies

Author(s):  Claudio Cimetta

Materials from this session:

Further details about this event:

 

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