LAWS6129 - Taxation of Controlled Foreign Companies, Foreign Investment Funds & Transferor Trusts
Objectives
- Understand the policy for the taxation of Australian residents with interests in foreign entities in relation to the removal of deferral, including an examination of the Board of Taxation review of anti-deferral rules.
- Learn the technical detail of the anti-deferral rules, namely CFCs, FIFs, transferor trusts and deemed present entitlement rules.
- Apply the rules to current practical problems involved in the taxation of interests in offshore entities.
Content
Concept of deferral; CFCs; FIFs; transferor trusts; and deemed present entitlement rules.
Session
Semester 2 2010
Thursday Evenings, 6-8pm
The timetable is subject to frequent changes. Please refer to the latest version of the Postgraduate Timetable.
Assessment
- 1 x 3,000 Word Assignment (30%)
- 1 x Exam (70%)
Assumed Knowledge
It is recommended that candidates who are not working in the tax area and have not taken an undergraduate tax unit in Australia in the past five years undertake LAWS 6128 - Comparative International Taxation or LAWS 6825 - Impact of Tax on Business Structures & Operations before enrolling in this unit. If in doubt, please consult the Taxation Program Coordinator.
Courses this unit is available in
Master of Laws | Graduate Diploma in Law | Master of Global Law | Master of Business Law | Master of International Taxation | Master of Taxation | Graduate Diploma in Taxation