shopping_cart

Your shopping cart is empty

Corporate residency and private groups podcast

Published on 09 Jun 21 by SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE

This podcast covers:

  • Quarantining the profits of the foreign entity at the foreign corporate tax rate (subject to Australia’s CFC rules and transfer pricing regime)
  • Accessing the dividend exemption under Subdivision 768-A ITAA 1997
  • Accessing CGT reductions under Subdivision 768-G ITAA 1997
  • Application of s23AH branch exemption to ‘foreign’ subsidiaries
  • Determining the members of a tax consolidated group and whether foreign subsidiary members may be considered part of an Australian group depending on where decisions are made
  • Whether the CFC rules apply to the entity and implications for common foreign ‘hybrid’ flow through entities
  • Application of Australia’s double tax treaties.

Author profile

Philip Shepherd CTA
Phil is a Director at KPMG and a tax specialist working primarily with middle market corporates and large family groups. With over 13 years of experience providing tax advice to domestic and international groups, Phil has a passion for seeing global businesses thrive in South Australia. Phil has a broad skillset which includes advising significant global entities on tax risk management, structuring private groups for divestment or IPO and developing succession and estate planning strategies for high net worth families. Phil is a Chartered Tax Advisor and a member of the Institute of Chartered Accountants. - Current at 11 January 2021
Click here to expand/collapse more articles by Phil Shepherd.

 

This was presented at 2021 Barossa Convention .

Get a 20% discount when you buy all the items from this event.

Individual sessions






Lost in (company) losses

Author(s):  Sean VAN DER LINDEN

Materials from this session:

Tax Policy and Advocacy Update

Author(s):  Robyn Jacobson,  Scott TREATT

Materials from this session:

Professional firm structuring & professional firm allocation of profits

Author(s):  Michael Butler,  Tom Hendrick

Materials from this session:

Discretionary Trusts – Issues: New and old

Author(s):  Julie VAN DER VELDE

Materials from this session:

The Post-COVID wasteland impacting SME deals

Author(s):  Simon HOW

Materials from this session:

Further details about this event:

 

Copyright Statement
click to expand/collapse