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Foreign investment fund changes emerging from the Review of International Taxation Arrangements seminar paper
Published on 22 Sep 04 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
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?
Author profile
Philip Barlin CTA
Philp Barlin, FTIA, is currently Executive Manager Taxation at the Commonwealth Bank. He has 25 years of experience in the taxation field both in professional firms and corporates. Philip is currently chair of the First State Colonial tax working group and has for many years specialised in the taxation aspects of the wealth management industry. - Current at 05 April 2012
This was presented at NSW International Masterclass .
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Individual sessions
International Tax Reform
Author(s): Peter MCCULLOUGH, John ALLENMaterials from this session:
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Foreign investment fund changes
Author(s): Philip BARLINMaterials from this session:
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Recent transfer pricing developments
Author(s): Stephen BRECKENRIDGEMaterials from this session:
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A practical look at source issues
Author(s): Bill CANNON, Peter EDMUNDSONMaterials from this session:
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Cross border investment/cross border financing
Author(s): Peter MADDENMaterials from this session:
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