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Workshop 4 case studies and answers: International

Published on 25 Oct 12 by NATIONAL DIVISION, THE TAX INSTITUTE

This workshop covered current technical issues raised by international tax measures (outside of the accruals regimes).

The case studies consider:

  • specific limitations on finance deductions (ie ss 25-85 and 25-90, and TOFA equivalent and thin capitalisation)
  • claiming FITO – allowable taxes and calculation of offset
  • Division 855 – the application of the division
  • foreign company share disposals – determining the active asset exemption
  • CFI – what are the issues associated with determining and declaring a CFI amount?

Author profiles

Tracey Rens CTA-Life
Photo of author, Tracey RENS Tracey is a partner in Deloitte Sydney’s Business Tax Advisory practice. She has over 20 years experience in providing advice on all major areas of Australian tax, including capital gains tax issues relating to acquisitions, divestments and restructures, loss management and integrity issues, capital allowance provisions, repatriation matters, tax consolidation and IFRS. - Current at 29 May 2019
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Narelle McBride CTA
Narelle McBride, CTA, is a Managing Director at PwC with over 25 years’ experience advising some of Australia’s largest corporate and privately owned enterprises, comprising varying business structures such as companies, trusts, partnerships and joint ventures. Her clients conduct business across many sectors including retail, property, primary industries and energy and resources. Narelle advises on general income tax matters as well as Australian tax issues associated with restructures, acquisitions and divestments. This extends to planning, due diligence and managing ATO interactions, reviews and disputes. She also advises on internal and external restructures involving debt financing arrangements, rehabilitation projects and closure projects. - Current at 29 January 2026
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Alyson Rodi ATI
Alyson is a Tax Partner at Deloitte in Sydney specialising in International and Corporate Tax. Alyson has over 20 years experience advising clients on inbound and outbound cross-border transactions including tax-effective cross-border financing and profit extraction strategies, the application of double tax treaties, the applicability of Australia's foreign accruals rules and potential foreign tax issues. In addition to Alyson's extensive Australian experience, Alyson also has experience working in the international tax groups of Deloitte's London and Dublin offices and working for a major London law firm. - Current at 29 January 2015
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This was presented at 2012 Tax Specialists' Workshop .

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

Individual sessions

Workshop 1 case studies and answers: Part IVA

Author(s):  David MARSCHKE

Materials from this session:

Workshop 4 case studies and answers: International

Author(s):  Tracey RENS,  Narelle MCBRIDE,  Alison RODI

Materials from this session:

Workshop 3 case studies and answers: M&A

Author(s):  Eddy MOUSSA

Materials from this session:

Workshop 2 case studies and answers: Managing tax disputes

Author(s):  Joanne DUNNE,  Michael CLOUGH,  Chris KINSELLA,  Peter COAKLEY

Materials from this session:

Further details about this event:

 

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