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Renovating the CFC and FIF regimes and rethinking outbound structures paper


This paper covers:

  • explanation of proposals
  • aspects of the ed on CFCS requiring further consideration and review
  • rethinking current structures.

Author profiles

Peter Madden CTA
Peter leads Deloitte Australia’s international tax group. Peter has over 27 years’ experience advising multinational corporations, investment banks and private equity firms on international and corporate tax matters. Peter has extensive experience in advising on investment into and out of Australia as well as significant transaction experience in most industry sectors. - Current at 18 July 2011
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Alyson Rodi ATI
Alyson is a Tax Partner at Deloitte in Sydney specialising in International and Corporate Tax. Alyson has over 20 years experience advising clients on inbound and outbound cross-border transactions including tax-effective cross-border financing and profit extraction strategies, the application of double tax treaties, the applicability of Australia's foreign accruals rules and potential foreign tax issues. In addition to Alyson's extensive Australian experience, Alyson also has experience working in the international tax groups of Deloitte's London and Dublin offices and working for a major London law firm. - Current at 29 January 2015
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This was presented at International Masterclass .

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Individual sessions

Renovating the CFC and FIF regimes - Where are we at?

Author(s):  Alison RODI

Materials from this session:

IBM on withholding - What it means

Author(s):  Simon THORP,  Erin Saunders

Materials from this session:

Reportable tax positions

Author(s):  Miquel P. TIMMERS

Materials from this session:

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