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NSW International Masterclass
Published on 22 Sep 2004 | Took place at The Radisson Hotel, Sydney, NSW
International Tax Reform continues to dominate the current tax reform landscape with the recent release of long awaited legislation. These seminar materials provide the ideal opportunity to take stock on where the reform is at as well as reviewing the upcoming reforms and their impact on you.
Leading practitioners critique the changes and examine their practical application.
For those practitioners in the International Tax arena, these seminar materials will provide valuable insights into the likely tax issues facing us for years to come.
Get a 20% discount when you buy all the items from this event.
Individual sessions
International Tax Reform
Author(s):
Peter MCCULLOUGH,
John ALLEN
This paper covers the following topics:
- background
- CGT exemption for sale of shares in active CFCs
- attribution of income from BELC-based companies
- intra-group investments between CFCs and the tainted services changes.
Materials from this session:
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Foreign investment fund changes
Author(s):
Philip BARLIN
This paper covers:
- the changes so far - increasing balanced portfolio exemption, super exemptions, etc. - what are the practical issues?
- the changes introduced - treaty changes for investors in trusts, WHT for rent, direct and indirect CGT exemptions for offshore investors - what systems and other changes are required and by when?
- the changes still to come - the broad 10% balanced portfolio exemption, how can we design a better FIF regime?
- interaction with other changes - what do the participation and exemption changes mean for FIF interests? What about other kinds of non-FIF foreign interests?
Materials from this session:
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Recent transfer pricing developments
Author(s):
Stephen BRECKENRIDGE
This paper covers the following topics:
- level of disclosure - impact of Consolidated Schedule 25As
- simplified disclosures for SMEs
- effect of differing accounting and tax characterisations
- impact of upcoming changes to accounting standards and benchmarking analysis
- current ATO audit activities
- comparative issues/APAs.
Materials from this session:
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A practical look at source issues
Author(s):
Bill CANNON,
Peter EDMUNDSON
This seminar paper covers the following topics:
- impact of moving to a more residence based treaty policy
- impact of OECD clarification of PE and income allocation
- consequences of applying source rules to e-commerce transactions.
Materials from this session:
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Cross border investment/cross border financing
Author(s):
Peter MADDEN
This paper covers the following topics:
- choice of investment entity
- profit repatriation
- exit strategies
- hybrid instruments
- gearing issues.
Materials from this session:
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