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).
Sue is a Partner at Clayton Utz specialising in taxation and stamp duty. She has represented a range of significant clients on the full spectrum of taxation matters including advising on transactions, international tax, general corporate tax and tax litigation. Sue has participated on various committees and consults with Treasury and the ATO on taxation issues.
- Current at
15 April 2011