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The expanding offshore client

Published on 01 Sep 17 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

Australia’s tax system contains complex rules for Australian entities that wish to expand offshore. The rules can be a minefield and often present difficulties for tax advisers, particularly where they involve applying Australian tax concepts in foreign jurisdictions. This article is intended to provide an overview of the different rules that can apply to Australian entities expanding offshore. While the focus of the article is on offshore investments via a corporate entity, specific issues regarding investments through non-resident trusts are also discussed. The article opens with discussion of basic concepts, including residency and types of entity. The article then discusses in detail what is involved in expanding offshore through a corporate entity, including discussion of the CFC rules. The article concludes with a briefer examination of expansion offshore through a trust.

Author profile

Cameron Blackwood ATI
Cameron brings more than a decade of transactional tax expertise to his role as Partner in Greenwoods & Herbert Smith Freehills’ Sydney office. He specialises in advising clients on the tax complexities of mergers, acquisitions and restructures, including capital management and cross-border issues, and all aspects of employee share schemes; and regularly works in close collaboration with Herbert Smith Freehills. Cameron has also been involved in undertaking tax due diligence for insurers providing warranty and indemnity insurance in M&A transactions. He is a trusted adviser for a number of Australia’s largest taxpayers. By way of example, in 2018 Cameron was the lead adviser on two of the largest transactions in Australia, being the Wesfarmers demerger of Coles and the BHP Group off-market share buy-back. Cameron has also been heavily involved in recent ATO and Treasury consultation on capital management, cross-border and employee share scheme issues. Cameron has been recognised in The Legal 500 Asia Pacific 2021; Best Lawyers 2020 for Tax in Australia, as well as a Leading Lawyer by Doyle’s Guide. In 2019 Cameron was also a finalist for Taxation Partner of the Year at the Lawyers Weekly Partner of the Year Awards and was a finalist in 2020 for The Tax Institute's Corporate Tax Adviser of the Year. Cameron is a member of The Tax Institute’s Large Business and International Committee and NSW Technical Committee. He holds a Bachelor of Business (Hons) and Bachelor of Laws (Hons) from the University of Technology, Sydney, and a Master of Taxation from the University of Sydney. Cameron is admitted as a solicitor in New South Wales. - Current at 13 August 2021
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