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International trusts paper


This paper focusses on tax planning for individuals who migrate from the United Kingdom or New Zealand to Australia, or from Australia to either of those countries. It considers the tax issues that arise where the client controls trusts established in the country of entry or exit:

  • determining whether a trust is an Australian resident
  • Australian tax consequences of foreign trusts earning income from 'tax haven' countries
  • advising a NZ or UK resident client changing residence to Australia of tax consequences for controlled foreign trusts
  • advising a client of the Australian tax consequences for a controlled foreign trust if client becomes a non-resident.

Author profile

Campbell RANKINE
Campbell has practised law for the past 40 years, specialising in revenue law, with an emphasis on taxation of cross-border transactions, stamp duty, superannuation, capital gains taxes and similar advices, often advising other law firms and accountants. Prior to his admission he practised for 14 years as a Chartered Accountant. Campbell is currently undertaking his PhD thesis on taxation of trusts and their beneficiaries. He is a Member of many Taxation Institute Committees.
Current at 16 October 2007
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This was presented at 14th National Tax Intensive Retreat: Trusts Under the Microscope .

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Individual sessions

Workshop 1: CGT small business concessions

Author(s):  Moira MERRICK

Materials from this session:

Workshop 2: Trust distributions, testamentary trusts and amending trust deeds

Author(s):  Andrew Noolan

Materials from this session:

Further details about this event:


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