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Reform of the anti-tax deferral rules: An update


This article discusses and analyses developments in relation to the reform of Australia's anti-deferral rules, in particular, the proposed rewrite of the controlled foreign company (CFC) rules, the repeal of the foreign investment fund (FIF) rules and the introduction of a modified distribution exemption (to replace section 23AJ of the Income Tax Assessment Act 1936).

Author profiles

Jane Michie
Photo of author, Jane MICHIE Jane is an Executive Director at Macquarie Group in the Taxation Division. She specialises in income tax issues, particularly international tax and the taxation aspects of the financial services industry. Jane is heavily involved in the consultation process with Treasury on the proposed changes to the anti-deferral measures. - Current at 10 November 2011
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Cameron Blackwood ATI
Cameron brings more than a decade of transactional tax expertise to his role as Director in Greenwoods & Herbert Smith Freehills’ Sydney office. He specialises in advising clients on the tax complexities of mergers, acquisitions and restructures, including cross-border issues and all aspects of employee share schemes, and regularly works in close collaboration with Herbert Smith Freehills. After joining Greenwoods & Herbert Smith Freehills as a graduate in 2004, Cameron built his corporate experience advising companies on a wide range of advisory and compliance matters, including a secondment to BHP Billiton. His industry knowledge is broad and includes the mining, real estate and financial services sectors. Cameron is also a key member of the firm’s Private Wealth group, which advises many of the country’s most successful private groups and emerging entrepreneurial businesses. Cameron is a member of The Tax Institute’s Large Business and International Committee and the NSW Technical Committee. He holds a Bachelor of Business (Hons) and Bachelor of Laws (Hons) from the University of Technology Sydney, and a Master of Taxation from the University of Sydney. Cameron is admitted as a solicitor in New South Wales. - Current at 26 June 2019
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