Published on 01 Aug 04
by "THE TAX SPECIALIST" JOURNAL ARTICLE
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.
Mark is a Partner in the International Tax & Transaction Services Group in the Sydney office of PricewaterhouseCoopers. Mark has over 12 years experience in corporate and international taxation and has also worked in the United States. Mark specialises in international tax and regularly advises clients on taxation issues arising from M&A transactions, cross-border financing arrangements and corporate restructures.
Current at 23 August 2006 Current at 25 June 2013
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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 August 2004 Current at 23 October 2007
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