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The curious reform of foreign source income
Published on 01 Aug 18 by "THE TAX SPECIALIST" JOURNAL ARTICLE
Proposals currently before parliament which change the tax treatment of foreign source income seem to have been largely overlooked. They deserve greater attention because they produce curious and potentially illogical outcomes for many classes of Australian taxpayers. They are the unpublicised consequences of choices made in the design of Australia’s anti-hybrid rules, rules which were intended to curb the aggressive tax avoidance practices of multinational enterprises. Instead, they extend to many types of resident taxpayers earning some classes of foreign source income. This article demonstrates how entirely innocuous situations can be affected and how the impacts can be quite unexpected.
Author profile
Prof Graeme Cooper FTI
Graeme Cooper, FTI, is an Emeritus Professor at Sydney University Law School and consultant to Herbert Smith Freehills. He is a former Chair of the New South Wales State Council of The Tax Institute and former member of the National Council. He has worked as a consultant to the ATO, Treasury, Board of Taxation, United Nations, OECD, World Bank, the International Monetary Fund and several foreign governments. He was admitted to legal practice in New South Wales and Victoria, and practised commercial law and tax in Sydney before entering teaching. He has taught in law schools in Australia, Europe, Canada and the United States, and holds degrees from the University of Sydney, University of Illinois and Columbia University, New York. - Current at 18 July 2023
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