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International Tax Reform delivered - the Participation Exemption and Other Measures - Part I


Government recently enacted a new participation exemption, which applies to the sale of non-portfolio interests in foreign companies that carry on an active underlying business. This article considers the scope of the provisions and discusses some of the issues likely to arise in their application.

Author profiles

Zorach Diskin FTI
Zorach is a Principal in the International Tax Services Group of Ernst & Young. For over 10 years he has advised major Australian and foreign multinationals on the tax implications of cross border investments. Prior to joining the profession Zorach was with the ATO where he spent five years in the ATO's Policy and Legislation Division. Much of that time he was engaged in developing the CFC measures. Since joining the profession Zorach has also been involved with the Tax Office's National Tax Liaison Group Foreign Source Income Sub-Committee. - Current at 01 August 2004
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Mark Hadassin CTA
Mark is a partner in the Deloitte International Tax Group in Australia specialising in international tax and infrastructure investment. Mark has over 20 years experience providing advice to major Australian and foreign corporates on domestic and international tax issues. Prior to joining Deloitte in January 2010, Mark spent 2 ½ years as Global Head of Tax at the Babcock & Brown group where he had responsibility for all the group's tax matters. - Current at 08 July 2014
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