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Offshore wealth - Accessing money overseas paper


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.

Author profile

Christopher Wookey CTA
Photo of author, Chris WOOKEY Chris Wookey, CTA, was a principal in the tax consulting division of Deloitte Private in Melbourne. He has over 30 years' experience in the chartered accounting profession and is a member of The Tax Institute's SME & Tax Practitioner Technical Committee and the Victorian State Technical Resource Committee as well as a regular presenter at its events. His experience, centred on issues encountered by private groups, includes advising about the tax treatment of accessing wealth accumulated in various structures such as trusts, superannuation funds and especially companies, in addition to having been involved in the early confidential consultations about the upcoming Div 7A reforms. - Current at 13 February 2019
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This was presented at 17th National Tax Intensive Retreat: Extracting Value .

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Individual sessions

Recent developments relating to discretionary trusts - getting money out of trusts against the wishes of the trustee & appointor

Author(s):  Lisa HESPE

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