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Workshop 4 case studies and answers: International

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?

Author profiles

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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Tracey Rens CTA
Photo of author, Tracey RENS 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 19 May 2017
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Narelle McBride CTA
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 02 June 2015
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This was presented at 2012 Tax Specialists' Workshop .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Workshop 1 case studies and answers: Part IVA

Author(s):  David MARSCHKE

Materials from this session:

Workshop 4 case studies and answers: International

Author(s):  Tracey RENS,  Narelle MCBRIDE,  Alison RODI

Materials from this session:

Workshop 3 case studies and answers: M&A

Author(s):  Eddy MOUSSA

Materials from this session:

Workshop 2 case studies and answers: Managing tax disputes

Author(s):  Joanne DUNNE,  Michael CLOUGH,  Chris KINSELLA,  Peter COAKLEY

Materials from this session:

Further details about this event:

 

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