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Changes to the foreign tax credit regime - a high level study presentation
Published on 19 Sep 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- abolition of class quarantining
- loss of carry forward rules
- changes to credits for underlying tax
- other implications.
Author profile
Jeremy Hirschhorn CTA
Jeremy Hirschhorn was appointed to the Second Commissioner role from 16 April 2020. He has overall responsibility for the ATO’s Client Engagement Group, which fosters willing participation in Australia’s tax and super systems through well-designed client experiences. Jeremy has more than 20 years' experience in roles managing complex tax matters. As Deputy Commissioner of Public Groups & International from April 2015, Jeremy was responsible for ensuring that the largest Australian and multinational companies were meeting their corporate tax obligations and providing the Australian community with confidence that these large companies were being held to account. Jeremy also worked as Chief Tax Counsel, with responsibility for the provision of the ATO’s legal advice in relation to interpretation of the tax and super laws, when he joined the ATO in August 2014.Prior to joining the ATO, Jeremy was a senior partner in KPMG’s tax practice. Jeremy holds a Bachelor of Commerce and Bachelor of Laws from the University of NSW. He is a Chartered Tax Adviser and Chartered Accountant. - Current at 12 January 2023
This was presented at International Tax Masterclass .
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Individual sessions
Foreign hybrid entity rules - close but not close enough
Author(s): Neil BILLYARDMaterials from this session:
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Changes to the foreign tax credit regime - a high level summary
Author(s): Jeremy HIRSCHHORNMaterials from this session:
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Thin capitalisation - a selection of issues
Author(s): Geoffrey DUNNMaterials from this session:
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Withholding tax considerations
Author(s): Justin CHERRINGTON, James WILLISMaterials from this session:
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Interpretation of double tax agreements
Author(s): Richard SHADDICKMaterials from this session:
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Substantial equipment
Author(s): Adrian O'SHANNESSYMaterials from this session:
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Strategies for managing offshore taxation obligations and risks
Author(s): Margherita ANTONELLI, Jon DOBELLMaterials from this session:
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The new withholding obligations
Author(s): Andrew MILLSMaterials from this session:
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