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Back to the future: attribution of futures contract gains under Australia's CFC regime

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Published on 01 Apr 06 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Australia’s Controlled Foreign Company (“CFC”) rules have been the subject of several major reforms in recent years. The reforms have changed the scope of these rules, however, the CFC rules continue to be a significant risk area for taxpayers engaging in international transactions. This paper will focus on one particular type of transaction, namely the potential attribution under the CFC rules of gains made in respect of forward and futures contracts.

Author profile

Dr Philip Bender ATI
Dr Philip Bender, ATI is a barrister at the Victorian Bar. He is the author of Bender’s Australian Stamp Duties, published by the Tax Institute. He acts in Federal and State taxation, superannuation, and trusts and estates matters for taxpayers and revenue authorities. In the trusts area, he has acted in many taxation disputes involving trusts issues, and has acted in many trusts matters involving, amongst other topics, trust deed and will interpretation, alleged breaches of trust; trustee removal applications; judicial advice; charitable trusts; and superannuation death benefits disputes. - Current at 06 March 2023
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