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CFC & FAF changes - A property perspective presentation


This presentation covers:

  • where have we come from?
  • what do we have now?
  • what are the proposed new CFC & FAF rules?
  • proposed CFC rules - issues for the property industry:
    • rental exclusion
    • control
    • grouping relief
    • carve outs
    • non-portfolio dividends
  • proposed FAF rules - issues for the property industry:
    • fixed trusts
    • other issues
  • rethinking of common property structures
  • where to from here?

Author profiles

Max Persson
Max is a Tax Partner with the Deloitte Real Estate Group specialising in corporate and international tax. He has over 12 years of tax experience and works with a number of large multinational diversified property groups, including stapled entities, as well as construction companies, property developers, retirement village operators and property funds. Max has a deep understanding of the taxation of direct property investments and the establishment of real estate fund structures for domestic and offshore investors and maintains strong relationships with Deloitte global property tax specialists. He is a member of the Property Council of Australia Income and International Tax Committee, having been involved in lobbying on a number of key reform areas including tax preferred entity financing, taxation of financial arrangements, foreign income attribution and the managed investment trust regime. - Current at 15 September 2017
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Joe Galea
Joe is a Corporate Tax Partner with the Deloitte Real Estate Group. He has over 15 years of corporate tax experience with a particular emphasis on advising property groups, including listed and unlisted funds, large multinational property groups and offshore investors. He has advised in respect of a number of significant tax consolidation projects for property groups, including considering the impact of the recent amendments to the tax cost setting rules. Joe is also an active member of the Property Council of Australia’s Income and International Tax Working Group. - Current at 30 August 2017
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This was presented at 9th Annual Property Intensive .

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