Published on 17 Apr 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper focusses on Australia's non-resident tax initiatives and considers how the rules operate to benefit corporate and non-corporate taxpayers alike. Issues covered include:
- non-resident CGT rules: what CGT assets remain within Australia's tax net? Ongoing relevance of income / capital distinction? Reconciling domestic law with Australia's DTAs. Practical inbound structures for non-residents
- temporary resident rules: Who qualifies? What income is concessionally taxed? In what circumstances?
- conduit foreign income rules: How they operate? How non-resident stakeholders benefit? How resident Australian companies benefit?
- other favourable international tax initiatives (23AJ, 23AH, CGT relief for active foreign companies, CFC & FIF changes).
Michael Taylor-Sands FTI
Michael is a Partner with Maddocks. He joined the Revenue Group of Maddocks in 2005 having previously been a Senior Associate at Baker & McKenzie. Michael has considerable experience in consulting on income tax and state tax issues to a wide range of corporate and non-corporate clients. He has advised large multi-national and Australian corporate groups in the manufacturing, property development/investment and gaming/casino industries. Current at 15 April 2011
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