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Infrastructure and property investment - taxpayer and ATO perspectives presentation


This presentation covers:

  • Division 6B - dinosaurs still have big teeth
  • Division 6C - the industry has outgrown it, are we at risk of falling behind world’s best practice?
  • stapling - how does it work and why does the ATO have issues with it?
  • distributions of income and capital - yield is king but tax deferred isn’t far behind
  • going offshore - 6C, DTAs and other obstacles to a simple commercial structure
  • trust taxation and the Division 6B and Division 6C alternatives
  • excepted trusts and their exclusively ‘eligible investment business’
  • stapling structures
  • are interests in stapled entities ‘listed’? - Implications for tax treatment of stapling
  • interaction with capital streaming.

Author profiles

Simon Clark CTA
Simon is a Director of Greenwoods & Freehills Pty Limited. Simon is involved in providing day to day and transactional, income tax and GST advice mainly in the funds management sector. He has also been extensively involved in assessing the implications of tax reform on clients including involvement in lobbying on the Australian REIT rules, the MIT provisions and various current Board of Tax reviews. Simon is a member of the Property Council’s National Tax Group and the ICAA Tax Technical Committee. He sits on a number of consultative committees including those dealing with Tax Treaties and Finance and Investments - Current at 08 July 2011
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Christopher Hood CTA
Chris Hood is presently a Senior Tax Counsel in the Australian Taxation Office. He has an extensive background in several areas related to trust taxation, including the operation of Divisions 6C and 6B of the Income Tax Assessment Act 1936. He worked as a member of the secretariat to the Review of Business Taxation (the Ralph Review). Before joining the ATO in 1984, and an extended career in legislative instructing work, Mr Hood was a solicitor in private practice in Sydney. - Current at 11 May 2010
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This was presented at 2007 Financial Services Taxation Conference: Financial Services Unleashed .

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Individual sessions

Infrastructure and property investment - taxpayer's and ATO perspectives

Author(s):  Simon Clark,  Christopher HOOD

Materials from this session:

Revenue losses and capital gains

Author(s):  John W DE WIJN

Materials from this session:

Retail financial products

Author(s):  Kirsten FISH

Materials from this session:

Promoter penalties and financial product providers - a provider's perspective

Author(s):  Glenn HUNTER

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Innovative capital raisings

Author(s):  Vik KHANNA

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Developments in cross border financial transactions - advisor responds

Author(s):  Andrew MILLS

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