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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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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 30 November 2020
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Christian Holle ATI
Christian is a Partner with PricewaterhouseCoopers - Current at 01 February 2015
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Lynnette Kelly CTA
Photo of author, Lynn Kelly Lynn is the Chief Adviser, Corporate and International Taxation, at the Department of Treasury. She has substantial private sector tax experience, previously leading the Commonwealth Bank of Australia's Tax Advising team and as well as tax manager roles with Fairfax Media, Thomas Cook/Travelex and PricewaterhouseCoopers. Working across these very different organisations has given Lynn a real insight into how leadership styles shape the culture and success of an organisation and the tangible value diverse teams deliver. Lynn is a member of Treasury’s Inclusive Workplace Committee, previously being a member of various diversity councils within the Commonwealth Bank. - Current at 08 January 2019
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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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