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International Tax Masterclass 2005

Published on 27 Oct 2005 | Took place at Dockside Function Centre, Darling Harbour, NSW

This masterclass consisted of seven cutting-edge sessions ranging across the entire spectrum of Australian international tax. The seven topics cover:
- a review of RITA from a senior Treasury officer
- the corporate aspects of the recent RITA reforms from two leading international tax experts from one of the 'big four' accounting firms
- CFC and treaty developments from two of the country's leading international tax law professors
- a discussion of developments in the areas of foreign trusts and transfer pricing from two senior international tax lawyers.

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Individual sessions

International comparative on holding companies

Author(s):  Peter MADDEN This paper provides an analysis of the tax regime for Australian holding company structures in light of the RITA changes and provides a comparison to the holding company tax regimes found in other common holding company jurisdictions.

Materials from this session:

Reform of the taxation of foreign trusts in Australia and the US - a comparative analysis

Author(s):  Christopher J BEVAN This paper provides an overview of the Australian taxation of foreign trusts - the transferor trust, deemed entitlement and FIF regimes, as well as an overview of the US taxation of foreign trust regimes - the US reforms since 1997. What is driving these reforms? Is Australia out-of-step with the US?

Materials from this session:

Current tax treaty issues related to interpretation

Author(s):  Richard J VANN

Although not much has happened on the surface since the US protocol and UK treaty were signed, Australia has actively been renegotiating treaties. In addition the ATO and the OECD produce a stream of treaty related material and the legislature tweaks domestic law to fit with treaties better (eg for employee share options). Issues covered in this paper include:

  • what have been the flow on impacts of the US / UK Treaty protocols?
  • what are the current trends for upcoming treaty negotiations?
  • recent OECD developments and recent Australian rulings and treaty related legislation.
Materials from this session: