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Thin capitalisation a focus on trusts presentation
Published on 26 May 16 by VICTORIAN DIVISION, THE TAX INSTITUTE
This presentation covers:
- setting the scene (gearing and transparency landscape)
- domestic unit trusts – inward and outward investor regimes
- associate entities of outward investors
- public unit trusts and tracing
- when is a unit trust an FCAT?
- when is the worldwide gearing test available?
- s.820-37 90% assets test exemption
- s.820-39 exemption and securitisation vehicles.
Author profiles
Stephen Ford CTA
Steve Ford, CTA, is a Tax Partner at PwC, specialising in M&A in the infrastructure, PPP and energy sectors. Steve is a member of the IPA Tax Committee. Steve was previously an Executive Director with Macquarie Capital, specialising in project finance and infrastructure. - Current at 26 June 2019Angela Van
Angela is a Manager with PricewaterhouseCoopers.Current at 1 May 2016
This was presented at National Infrastructure Conference .
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Thin capitalisation - A focus on trusts
Author(s): Steve FORD, Angela VanMaterials from this session:
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Towards justified trust between the ATO and the infrastructure industry
Author(s): Jeremy HIRSCHHORNMaterials from this session:
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The imposition of Australian stamp duties on foreign entities
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Division 6C of the ITAA36 negative control
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Division 6C property funds - Land in the context of infrastructure
Author(s): Chris PEADONMaterials from this session:
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Tax sharing and tax funding agreements in a project financing context
Author(s): David WOODMaterials from this session:
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ATO areas of compliance focus
Author(s): Rhys MANLEY, Craig SAUNDERSMaterials from this session:
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The infrastructure market in Australia current themes and perspectives
Author(s): John PickhaverMaterials from this session:
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Section 974-80: The current state of play
Author(s): Richard BUCHANAN, Edward ConsettMaterials from this session:
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