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Offshore wealth - Accessing money overseas paper

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Published on 28 Aug 09 by NATIONAL DIVISION, THE TAX INSTITUTE

Clients accumulate wealth in a myriad of different ways and store it in nearly as many different structures - especially those clients who have migrated to Australia or returned from overseas postings. This paper focuses on characterising a number of the unusual arrangements advisers may encounter as well as highlighting the technical issues related to them and some strategies which may be adopted to mitigate the exposure to tax costs. Topics covered include:

  • types of foreign entities typically used for passive investment;
  • peculiar foreign entities and how they are regarded under Australian tax law (eg foundations, purpose trusts, anstalts, stiftungs, guarantee corporations, LLCs, LPs, LLPs, REITs, foreign retirement savings and cell insurance companies);
  • Section 99B issues for immigrants;
  • planning approaches when advising people intending to migrate to Australia;
  • cross-border loans; and
  • application of the reimbursement agreement rule in section 100A - taking money from Australia offshore and bringing it back again.

Author profile

Chris Wookey CTA-Life
Photo of author, Chris WOOKEY Chris Wookey, CTA (Life) operates his own specialist tax consulting practice after previously having been a principal in the tax consulting division of Deloitte Private in Melbourne. A finalist in The Tax Institute’s Tax Adviser of the Year Awards for 2020 and 2022 and made a life member of The Tax Institute in September 2023, he has over 30 years’ experience in the chartered accounting profession and is a member of The Tax Institute’s national SME Technical Committee and had been its representative on the ATO’s Private Groups Stewardship Group from 2021 to 2022. Chris was also a member of the Board of Taxation’s Reference Group for its Review of Small Business Tax Concessions. His experience, centred on issues encountered by private groups, includes providing input to Treasury in relation to the proposed targeted amendments to the Div 7A integrity rules and participating in confidential consultations with the ATO in relation to the 2022 and 2023 developments in relation to section 100A. - Current at 29 January 2026
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This was presented at 17th National Tax Intensive Retreat: Extracting Value .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Recent developments relating to discretionary trusts - getting money out of trusts against the wishes of the trustee & appointor

Author(s):  Lisa HESPE

Materials from this session:

Getting value out of companies - Part 1

Author(s):  Paul HOCKRIDGE

Materials from this session:

Getting value out of companies – Part 2

Author(s):  David MARSCHKE

Materials from this session:

Voluntary liquidation – Getting the money & assets out of a company

Author(s):  Michael BUTLER

Materials from this session:

Offshore wealth - Accessing money overseas

Author(s):  Chris WOOKEY

Materials from this session:

The trust has served its purpose - Now let’s get the money out

Author(s):  Ken SCHURGOTT

Materials from this session:

The trust has served its purpose: Now what can we do with it?

Author(s):  Grahame Young

Materials from this session:

Further details about this event:

 

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