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International tax reform - changes to the foreign income, CFC and capital gains tax rules presentation

Published on 22 Sep 04 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers the following topics:
- background
- CGT exemption for sale of shares in active CFCs
- attribution of income from BELC-based companies
- intra-group investments between CFCs and the tainted services changes.

Author profiles:

John Allen
John, of Deloitte Touche Tohmatsu, has 12 years experience in corporate and international taxation. He currently specialises in structured financing and mergers and acquisitions work, as well as continuing to supply general corporate tax advice to a number of leading clients. Current at 18 August 2006 Click here to expand/collapse more articles by John ALLEN.
 
Peter McCullough
Peter is the Global Practice Head Tax of Ashurst based in Sydney. Prior to joining Ashurst in 2010, Peter was a partner in the tax practice of Ernst & Young. He has over 27 years of experience advising on a wide range of Australian and international income tax matters, dealing with clients across a broad range of industries. Peter has presented at conferences in Australia and overseas on domestic and international tax issues, is an author of the LexisNexis publication Corporate Tax: Finance, Transactions, Distributions, and has written articles and tax commentary in a number of other professional publications. Current at 01 June 2015 Click here to expand/collapse more articles by Peter MCCULLOUGH.

This was presented at NSW International Masterclass.

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