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Workshop one - Outbound investment paper


This paper covers a CFC case study including:

  • identifying the CFC and attributable taxpayers CFC
  • tracing through CFCs
  • calculating attributable income for Irish Lease Co, Lux Fin Co and Caymans Hold Co
  • distributions paid to attributable taxpayer.

Author profiles

Jane Michie
Photo of author, Jane MICHIE Jane is an Executive Director at Macquarie Group in the Taxation Division. She specialises in income tax issues, particularly international tax and the taxation aspects of the financial services industry. Jane is heavily involved in the consultation process with Treasury on the proposed changes to the anti-deferral measures. - Current at 10 November 2011
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Christian Holle ATI
Christian is a Partner with PricewaterhouseCoopers - Current at 01 February 2015
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Cameron Blackwood ATI
Cameron brings more than a decade of transactional tax expertise to his role as Director in Greenwoods & Herbert Smith Freehills’ Sydney office. He specialises in advising clients on the tax complexities of mergers, acquisitions and restructures, including cross-border issues and all aspects of employee share schemes, and regularly works in close collaboration with Herbert Smith Freehills. After joining Greenwoods & Herbert Smith Freehills as a graduate in 2004, Cameron built his corporate experience advising companies on a wide range of advisory and compliance matters, including a secondment to BHP Billiton. His industry knowledge is broad and includes the mining, real estate and financial services sectors. Cameron is a member of The Tax Institute’s Large Business and International Committee and the NSW Technical Committee. He holds a Bachelor of Business (Hons) and Bachelor of Laws (Hons) from the University of Technology Sydney, and a Master of Taxation from the University of Sydney. Cameron is admitted as a solicitor in New South Wales. - Current at 25 September 2017
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Lynnette Kelly CTA
Photo of author, Lynn Kelly Lynn is an Executive Manager at the Commonwealth Bank of Australia and leads the Bank's Advising tax team. Her focus spans both international and domestic tax issues. Prior to joining the Bank in 2005, Lynn worked as a Tax Manager at Fairfax and Thomas Cook after beginning her career at PricewaterhouseCoopers. - Current at 26 February 2014
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This was presented at 2011 Tax Specialist Workshop .

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

Individual sessions

Workhop one - Outbound investment

Author(s):  Jane MICHIE,  Cameron BLACKWOOD,  Christian HOLLE,  Lynn Kelly

Materials from this session:

Workshop two - M&A transactions - Seller's perspective

Author(s):  David MARSCHKE,  Hayden BENTLEY,  Michael HENNESSEY,  Denise HONEY

Materials from this session:

Workshop 4 - Intellectual property

Author(s):  Peter FEROS,  Eddy MOUSSA,  Tracey RENS,  Robert Zalud

Materials from this session:

Further details about this event:


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