Miscellaneous 2007

Infrastructure and property investment - taxpayer and ATO perspectives

Source: National

Published Date: 15 Feb 2007


This presentation covers:

  • Division 6B - dinosaurs still have big teeth
  • Division 6C - the industry has outgrown it, are we at risk of falling behind world’s best practice?
  • stapling - how does it work and why does the ATO have issues with it?
  • distributions of income and capital - yield is king but tax deferred isn’t far behind
  • going offshore - 6C, DTAs and other obstacles to a simple commercial structure
  • trust taxation and the Division 6B and Division 6C alternatives
  • excepted trusts and their exclusively ‘eligible investment business’
  • stapling structures
  • are interests in stapled entities ‘listed’? - Implications for tax treatment of stapling
  • interaction with capital streaming.

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Miscellaneous 2007

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