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TOFA - A new world of economic substance? presentation
Published on 13 Feb 13 by NATIONAL DIVISION, THE TAX INSTITUTE
At its essence, TOFA attempts to systematically align the tax treatment of financial arrangements towards their economic substance rather than their legal form.
This presentation examines:
- how do the economic substance provisions work in practice?
- when does the economic substance approach not apply in practice, i.e. what might be the limits of this economic substance approach?
Issues considered include:
- economic substance under accounting principles
- interactions with other parts of the Act that impose non-economic substance-based approaches
- impact of tax character on substance-based analyses
- deliberate design features in Div 230 that move away from economic substance
- consideration of the synthetic disposal and non-disposal rules.
Author profile
Phillip Cole CTA
Phillip is Head of Tax, Australia and New Zealand at J.P.Morgan. He has spent nearly 20 years working in the internal tax functions at both Australian-based and foreign financial institutions, including eight years at the Commonwealth Bank of Australia. His experience covers the spectrum of tax issues affecting financial institutions with a particular focus on domestic banking issues, including extensive involvement in the TOFA reforms. Prior to corporate life, he spent seven years in chartered accounting. - Current at 13 February 2013
This was presented at 2013 Financial Services Tax Conference .
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Individual sessions
Topical tax treaty issues for the financial sector
Author(s): Richard J VANNMaterials from this session:
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The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks
Author(s): Ian FULLERTONMaterials from this session:
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Transfer pricing and funds management
Author(s): Damian PRESHAWMaterials from this session:
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Emerging regional issues (funds management)
Author(s): Daryl CHOO, Brian CHAMBERSMaterials from this session:
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The shifting Part IVA landscape
Author(s): Larry MAGID, James PETTIGREWMaterials from this session:
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Australian Taxation Office audits, risk identification, dispute
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GST and RITCs on trustee services
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Losses
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Capital management of financial institutions and the related tax issues
Author(s): Tricia HO-HUDSONMaterials from this session:
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The Rubik's Cube of tax - An update on trusts
Author(s): Andrew MILLS, Matt HARTSHORNMaterials from this session:
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New R&D regime in financial services
Author(s): Jamie MUNDYMaterials from this session:
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The promoter penalty regime - How the ATO ia applying it in practice
Author(s): Bruce COLLINS, Nathan FIRTHMaterials from this session:
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TOFA - A new world of economic substance?
Author(s): Phillip COLEMaterials from this session:
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Income tax case update
Author(s): Cameron RIDERMaterials from this session:
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Asset financing/thin capitalisation/infrastructure update
Author(s): Steve FORD, Arash AZIMIMaterials from this session:
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MRRT and Carbon Tax: Issues for financiers and funds
Author(s): Teresa DYSONMaterials from this session:
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