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Corporate residency and private groups video


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Member Price: $99.00
Non Member Price: $121.00

Publication date: 28 Apr 21 | Source: SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE

Abstract:
This video 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.

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Corporate residency and private groups
Author(s):  Phil Shepherd

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
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This was presented at 2021 Barossa Convention .

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