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Foreign entity classification in an outbound investment context and Double tax agreements and fiscally transparent entities presentation

Published on 18 Sep 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • overview of Australian Entities
  • overview of Foreign Hybrid Rules
  • classification of Foreign Entities
  • application of Foreign Hybrid Rules - Current Issues
  • how is a fiscally transparent entity (FTE) treated under double tax agreements?
  • is income derived by or through a FTE eligible for benefits under a DTA?
  • what are the issues on the application of DTAs to FTEs?
  • the OECD view
  • global responses
  • the Australian position(?)
  • case studies.

Author profiles:

David WATKINS
David is an International Tax Partner at Deloitte. David has over 20 years experience in corporate and international tax, including as a partner with Big 4 firms and a leading law firm. He has spent a number of years working in Malaysia and Singapore. David is a member of the ICAA International Tax Committee, has been a member of ATO / Treasury consultation committees and has appeared before Senate Committees on international tax matters. His experience includes a wide range of inbound and outbound structures with a focus on CGT, double tax agreements and foreign hybrids. His work has also included domestic and international tax issues associated with private equity and venture capital.
Current at 18 September 2008
Click here to expand/collapse more articles by David WATKINS.
 
Alison RODI

Click here to expand/collapse more articles by Alison RODI.

This was presented at International Tax Masterclass .

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

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Author(s):  Ian STANLEY

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