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Workshop one - Outbound investment paper
Published on 27 Oct 11 by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers a CFC case study including:
- identifying the CFC and attributable taxpayers CFC
- tracing through CFCs
- calculating attributable income for Irish Lease Co, Lux Fin Co and Caymans Hold Co
- distributions paid to attributable taxpayer.
Author profiles
Jane Michie
Jane Michie is an emerging non-executive director. She is an independent director of Chubb Insurance Australia, which is one of the largest general insurers in Australia. Jane is also a director of a corporate trustee for a charitable organization, a role she has held for 9 years.
In addition, Jane is a mentor & coach for emerging leaders in the corporate sector, and for women who have experienced homelessness including as a result of domestic violence.
Prior to embarking on a directorship career, Jane was a tax professional for nearly 30 years in the UK and Australia. Her most recent roles include: Global Head of Tax at BHP, Global Head of Tax at Macquarie Group and a partner of (what was) Greenwoods & Freehills.
Jane has 2 teenage sons and, in addition to her family, her passions include cycling and beach volleyball (although she advises she is not very good at either of them!)
- Current at
03 February 2023
Cameron Blackwood ATI
Cameron Blackwood, ATI, is the Head of Tax at Corrs and is a leading transactional tax expert, specialising in mergers, acquisitions, and restructures. Having advised several of Australia’s largest taxpayers, Cameron’s expertise includes cross-border issues and all aspects of employee share schemes. He has significant experience acting for public and private companies on capital management, including capital raising, return of capital, special dividends and buy-backs and debt raisings. He regularly presents at The Tax Institute and the Corporate Tax Association on M&A, management incentive plans and international tax issues and demergers. Cameron has been recognised as a leading lawyer by legal directories and publications including Chambers, The Legal 500 Asia Pacific and Best Lawyers for Tax in Australia. - Current at 30 May 2024Christian Holle
Christian is a Partner with PricewaterhouseCoopers - Current at 01 February 2015Lynnette Kelly CTA
Lynn Kelly, CTA, is the First Assistant Secretary for the Retirement, Advice and Investment Division at Treasury, who are responsible for providing policy and legislative advice to Government on initiatives to improve Australians’ financial security and raise retirement standards. Lynn’s previous roles at Treasury have included the Interim Chief Executive Officer of the Board of Tax and Chief Adviser, Corporate and International Taxation Division. Lynn joined Treasury’s Sydney office in December 2016 after over twenty years as a tax professional in the private sector where she worked across diverse industries, having previously lead the Commonwealth Bank of Australia’s Tax Advising team and as well as tax manager roles with Fairfax Media, Thomas Cook/Travelex and PricewaterhouseCoopers.
- Current at
21 August 2023
This was presented at 2011 Tax Specialist Workshop .
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Individual sessions
Workhop one - Outbound investment
Author(s): Jane MICHIE, Cameron BLACKWOOD, Christian HOLLE, Lynn KellyMaterials from this session:
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Workshop two - M&A transactions - Seller's perspective
Author(s): David MARSCHKE, Hayden BENTLEY, Michael HENNESSEY, Denise HONEYMaterials from this session:
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Workshop 4 - Intellectual property
Author(s): Peter FEROS, Eddy MOUSSA, Tracey RENS, Robert ZaludMaterials from this session:
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