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Around the World in 8 Hours

Published on 03 May 2006 | Took place at Swissotel, Sydney, NSW

As the Property Industry continues to evolve by local expansion and investment abroad, a host of local and international taxation issues are encountered. This seminar brought together speakers who are well equipped to lead you through the minefield as well as providing the opportunity to discuss the issues with your peers.

The seminar also highlighted the focus areas for the ATO and keeping us abreast of the relevant legislative changes over the past 12 months including the issues arising from the implementation of the International Financial Reporting Standards.

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Individual sessions

TOFA - the impact upon property entities

Author(s):  Joe GALEA

This paper covers:

  • what arrangements are caught by TOFA? - the definition of a financial arrangement
  • the application of TOFA to property related entities
  • some specific issues - deferred settlements, long term leaseholds, construction contracts
  • exceptions
  • application date and transitional provisions.
Materials from this session:

GST & property development

Author(s):  Andrew HOWE

This paper covers:

  • margin scheme: update and current issues
  • commercial residential: proposed new legislation
  • Division 129: repaying credits.
Materials from this session:

Stapling too far - Issues with stapling

Author(s):  Christopher HOOD

Topics covered in this paper include:

  • Stapling and association or relationship for tax purposes
  • Stapling and trust taxation treatment - Division 6B, Division 6C
  • Stapling and scrip rollover
  • Policy? Who mentioned policy? 
Materials from this session:

Issues for investing in US & European property

Author(s):  Chris MORRIS

Topics covered in this paper include:

  • Tax exemptions
  • Withholding tax - foreign tax credits
  • Maximising returns - e.g. tax deferred returns
Materials from this session:

Stamp Duty & Stapled Entities

Author(s):  Matthew STUTSEL

Topics covered in this paper include:

  • Acquiring assets
  • Syndicate/float impacts
  • Moving assets between entities
Materials from this session:

AIFRS

Author(s):  Marcus LEONARD

Topics covered in this paper include:

  • Fixed trust issues including units treated as debt, income distribution clauses, resettlements
  • Share capital tainting & disqualifying accounts
  • Thin capitalisation
  • Tax consolidation 
Materials from this session:

GST & Property Trusts

Author(s):  Matthew CRIDLAND

Topics covered in this seminar paper includes:

  • Leasing issues - inducements, fit-outs, long term leases, outgoings etc
  • Sale issues - SOGCs, rental guarantees
  • Trust establishments & apportionment issues
  • Grouping trusts and stapled entities 
Materials from this session: