Published on 25 Oct 12
by NATIONAL DIVISION, THE TAX INSTITUTE
This workshop covered current technical issues raised by international tax measures (outside of the accruals regimes).
The case studies consider:
- specific limitations on finance deductions (ie ss 25-85 and 25-90, and TOFA equivalent and thin capitalisation)
- claiming FITO – allowable taxes and calculation of offset
- Division 855 – the application of the division
- foreign company share disposals – determining the active asset exemption
- CFI – what are the issues associated with determining and declaring a CFI amount?
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
17 May 2017
Tracey is a partner in Deloitte Sydney’s Business Tax Advisory Practice. She has over 20 years’ experience in providing advice on all major areas of Australian tax including capital gains tax issues relating to acquisitions, divestments and restructures, loss management and integrity issues, capital allowance provisions, repatriation matters, tax consolidation and IFRS. Tracey is a Chartered Tax Advisor of The Tax Institute and Affiliate of the Institute of Chartered Accountants. She is currently the Vice President of The Tax Institute as well as serving on a number of national and NSW committees and has made numerous
presentations on corporate and international tax issues over the years. Tracey was also recognized in 2016 by the International Tax Review as one of Australia’s women in tax leaders.
- Current at
22 May 2017
Narelle is a Director in the Melbourne office of Greenwoods & Freehills. Narelle has extensive experience in advising on corporate tax matters such as corporate acquisitions and disposals, the tax consolidation regime more generally, and foreign investments in the resources and other industries. Narelle has also been involved in tax consolidation consultative forums and has assisted many clients in their dealings with the ATO on various corporate tax matters including tax consolidations, financial arrangements and foreign income.
- Current at
11 November 2015