Australia Trusts, Structures & International Guides
15 guides on Trusts, Division 7A, cross-border tax, transfer pricing, and non-residents.
Australia CFC & FIF Rules Guide (Controlled Foreign Companies, Foreign Investment Funds, Attributable Income)
Australian Controlled Foreign Company (CFC) and Foreign Investment Fund (FIF) rules — the 'CFC rules' (the 'attribution of the foreign income' to the 'Australian residents'), the 'FIF rules' (the 'foreign investment funds'), and the 'exemptions' (the 'de minimis', the 'active income' and the 'listed country exemptions').
Australia Corporate Trustee Tax Guide (Company as Trustee, Trust Tax Returns, Excepted Trust, Penalties)
Australian corporate trustee taxation — the 'company acting as the trustee of the trust', the 'trust tax return', the 'excepted trust rules', and the 'penalties for the corporate trustees'.
Australia Cross-Border Tax Guide (Foreign Resident Withholding, FIF Rules, Tax Treaties)
Australian cross-border and international taxation — the foreign resident withholding tax rates, the Foreign Investment Fund (FIF) rules, the tax treaties, the transferor trust rules, the foreign tax credits, and the CGT on the foreign assets.
Australia Division 7A Guide (Private Company Loans, Distributions, Complying Loans, Unpaid Present Entitlements)
Australian Division 7A — the 'deemed dividends' on the 'loans' and the 'advances' from the 'private companies' to the 'shareholders' and the 'associates', the 'complying loan agreements' (the 'interest rate' and the 'loan term'), and the 'unpaid present entitlements (the 'UPEs').
Australia Family Trusts Guide (Family Trust Election, Concessional Tax Rates, Trust Distributions, Streaming)
the Australian family trusts — the family trust election (FTE), the concessional tax rates for the beneficiaries, the trust distributions, the streaming of the income and the capital gains.
Australia Foreign Resident CGT Withholding Guide (FRCGTW 15%, Clearance Certificate, $750K Threshold)
Australian Foreign Resident Capital Gains Withholding (FRCGTW) — the '15% withholding' on the 'Australian property sales' by the 'foreign residents', the '$750,000 threshold', the 'clearance certificate', and the 'variation application'.
Australia Holding Companies & Corporate Groups Guide (Tax Consolidation, Group Relief, Inter-Entity Dividends)
Australian holding company and corporate group taxation — the tax consolidation regime (the single entity rule), the group relief (the loss transfer), the inter-entity dividends (the dividend exemption), and the structuring of the corporate groups.
Australia Non-Resident Taxation Guide (Tax Rates, Withholding, CGT, Property, Medicare)
Australian non-resident taxation — the non-resident tax rates (30% to 45%, no tax-free threshold), the withholding taxes (the dividends, the interest, the royalties), the CGT on the Australian property, the Medicare levy exemption, and the temporary resident rules.
Australia New Zealand Citizens Tax Guide (Trans-Tasman, Special Category Visa, Super, CGT, Medicare)
Australian tax rules for New Zealand citizens — the 'Special Category Visa (the 'SCV' — the Subclass 444)', the 'NZ citizens as the Australian residents for the tax purposes', the 'superannuation portability', and the 'CGT main residence exemption'.
Australia Permanent Establishment Guide (PE Risks, Branch Taxation, Double Tax Treaties, ATO Compliance)
Australian permanent establishment (PE) rules — the 'PE definition' under the 'Australian tax law' and the 'OECD tax treaties', the 'branch taxation' for the 'foreign companies with the PE in Australia', and the 'PE compliance' with the 'ATO'.
Australia Tax Treaties Guide (Double Tax Agreements, Withholding Rates, Treaty Benefits, Exchange of Info)
Australian double tax treaties — the 'Australian DTAs' with the '45+ countries', the 'treaty withholding rates on the dividends, interest, and royalties', and the 'treaty benefits' for the 'foreign residents'.
Australia Thin Capitalisation Guide (Debt/Equity Rules, Arm's Length Debt, Gearing Ratio, ATO Compliance)
Australian thin capitalisation rules — the 'debt to equity ratio' (the '1.5:1 safe harbour ratio'), the 'arm's length debt test', the 'worldwide gearing ratio', and the 'ATO compliance' for the 'inbound and the outbound investors'.
Australia Transfer Pricing Guide (Division 815, Arm's Length Principle, Documentation, Penalties)
Australian transfer pricing rules — the Division 815 of the ITAA 1997, the arm's length principle, the transfer pricing documentation (the TP documentation), the penalties for the transfer pricing adjustments, and the ATO compliance focus.
Australia Trust & Partnership Tax Guide (Trust Distributions, PSI, Streaming, Partnership Tax)
Australian trust and partnership taxation — the discretionary trusts (family trusts), the unit trusts, the trust distributions and the streaming, the Personal Services Income (PSI) rules, the partnership tax return, and the corporate beneficiaries.
Australia US Citizens Tax Guide (US-AU Tax Treaty, FATCA, FBAR, Dual Filing, Super, CGT)
Australian tax rules for US citizens living in Australia — the 'US-Australia tax treaty', the 'FATCA reporting', the 'FBAR reporting', the 'dual tax filing' (the 'US and the Australian tax returns'), and the 'tax treatment of the Australian superannuation for the US citizens'.