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US withholding taxes, franking credits and structuring

Published on 01 Feb 21 by "THE TAX SPECIALIST" JOURNAL ARTICLE

In this article, the author considers the impact of US withholding taxes and the foreign income tax offset on the application of the franking credit rules, with a case study illustrating the implications of US-sourced royalties for an Australian resident company in this context.

Author profile

Renuka Somers CTA
Renuka is the Senior Tax Advisor in the US-Australia Tax Desk at Asena Advisors in the US, and a consultant at HWL Ebsworth Lawyers, Australia. Her principal areas of practice are: US-Australia cross-border structuring, Australian federal taxes (income tax, mergers and acquisitions, CGT, Div 7A and tax consolidation), trusts and international estate planning for high wealth clients. She has written numerous articles for the Taxation in Australia and The Tax Specialist journals on these topics. Renuka has worked in large Australian law firms and international accounting firms, and has also served as a volunteer executive board member for a prominent Australian health promotion charity. - Current at 20 April 2020
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