Published on 28 Aug 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
This presentation focusses on three key areas arising from the proposed amendments in Tax Laws Amendment (2007 Measures No. 4) Bill. First, it examines the impact of the proposed removal of the foreign tax credit quarantining rules, considers the application of the transitional provisions that apply for taxpayers seeking to utilise existing carry forward tax credits, and highlights continuing issues for taxpayers seeking to utilise foreign tax credits. The presentation also touches on the interaction of the proposed foreign tax credit rules with the 'foreign hybrid' regime. Second, the presentation focusses on the impact of the proposed removal of the foreign loss quarantining rules, and the operation of the transitional provisions to convert existing foreign losses into tax losses. Finally, there is a discussion about the introduction of a Controlled Foreign Company calculation election for certain Foreign Investment Funds, including its interaction of the FIF rules with the proposed foreign tax credit rules.
Philip is a Barrister and member of the Institute of Chartered Accountants practising in State and Federal taxation, superannuation and commercial law. He is also a sessional member of the Victorian Civil and Administrative Tribunal (although he still appears as a barrister in the tax list of that Tribunal). Philip advises and appears for taxpayers and revenue authorities in State and Federal courts and tribunals and has appeared on a number of occasions in the High Court. He has also been briefed by other government agencies including ASIC, the Official Trustee in Bankruptcy and the Victorian Government Solicitor's Office.
- Current at
01 September 2011
James is a Partner with KPMG, and has been advising on corporate tax for 20 years. James is the leader of KPMG’s Tax Advisory Services business and is the Chair of KPMG’s Energy and Natural Resources group in Victoria. In addition he is a Senior Fellow of the University of Melbourne, lecturing in Mineral and Petroleum Tax.
- Current at
14 June 2017