Published on 28 Aug 09
by NATIONAL DIVISION, THE TAX INSTITUTE
Clients accumulate wealth in a myriad of different ways and store it in nearly as many different structures - especially those clients who have migrated to Australia or returned from overseas postings. This paper focuses on characterising a number of the unusual arrangements advisers may encounter as well as highlighting the technical issues related to them and some strategies which may be adopted to mitigate the exposure to tax costs. Topics covered include:
types of foreign entities typically used for passive investment;
peculiar foreign entities and how they are regarded under Australian tax law (eg foundations, purpose trusts, anstalts, stiftungs, guarantee corporations, LLCs, LPs, LLPs, REITs, foreign retirement savings and cell insurance companies);
Section 99B issues for immigrants;
planning approaches when advising people intending to migrate to Australia;
cross-border loans; and
application of the reimbursement agreement rule in section 100A - taking money from Australia offshore and bringing it back again.
Chris is a tax consulting director of GMK Centric (formerly Gaddie Metz Kahn), the accounting and
tax services division of Centric Wealth, and has nearly 20 years’ experience in the chartered
accounting profession. Over that time, he has advised many large corporates and international businesses, as well as privately owned groups, in relation to matters ranging from restructures, mergers and acquisitions to financing and profit distribution strategies. A fellow of the Taxation Institute and regular presenter at its continuing professional development seminars, Chris is a chartered accountant and holds the degrees of Bachelor of Business (majoring in accounting and economics) and Master of Taxation. Current at 10 August 2007
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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