s99B ITAA 1936 is about foreign trusts paying accumulated income to Australian resident beneficiaries. Take away one of these elements, and you don't have a s99B issue.
The theory around foreign trusts is confusing. So in this episode let's use a New Zealand trust as a foreign trust example.
Here are five transfer pricing examples that cover common transfer pricing issues.
A reasonably arguable position - a so-called 'RAP' - is essential to protect you from penalties and interest around transfer pricing.
You have seven options to qualify for the simplified transfer pricing record keeping as outlined in PCG 2017/2.
Transfer pricing is an issue whenever you deal with an associated entity overseas.
When you structure across the US - AU border, you easily run into the following six questions.
When your clients plan an expansion into the US, they will most likely ask you how to structure this.
How you structure your investment into US public and private markets depends on the following seven factors as Peter Harper of Asena Advisers will tell you in this episode.
Holding a 401K as an Australian tax resident can cost you a lot of tax - but there are ways around it.
When you move from the US back to Australia, your tax position faces two big issues: CGT and your 401k.
Non-ECI Non-FDAP - how is US sourced income that is neither ECI nor FDAP taxed in the US if derived by a non-resident?
How LLC income is taxed in the US - disregarding any treaty position - depends on three things as Gary Carter will tell you in this episode.
A single member LLC is a disregarded entity for US federal tax purposes. The Australian entity assumes all US federal tax obligations instead.
For US citizens living in Australia, the US taxation of Australian SMSFs is a huge question.
For an expansion into the US is it best if your Australian trust holds LLC interests directly? Rather than going through a C-Corp?
How to avoid tax leakage and double taxation when you expand your business overseas?
When you give an Australian loan to US operations, should you loan to your US blocker or directly to your US trading entity?
When would you set up an LLC plus blocker to expand into the US market? Marsha Dungog of Withers has the answer.
Inbound investments have implications for Australian tax. Clint Harding of Arnold Bloch Leibler in Sydney will tell you what they are.
How do you show Australian companies in US returns? Seth Hertz of US Expat Tax has the answer.
As a non-US tax resident, should you run your US business through an LLC or C-Corp?
To block or not to block - that is the question Clint Harding and Alex Rasmussen will discuss with you in this episode.
When your clients expand into the US, here are the types of US corporations to choose from.
Here are 7 important concepts in international tax. Understand those and you got the basics.
How to you expand into New Zealand? What GST and income tax implications does this have? Here is Mike Reddy of NZTax.com.au.
What happens to your tax position when you expand overseas? Here is Clint Harding of Arnold Bloch Leibler in Sydney with the anwer.
Investing in overseas shares through a company can result in withholding tax leakage as Clint Harding of Arnold Bloch Leibler will tell you.
How do you treat the US stimulus cheques in Australian tax returns? Seth Hertz of US Expat Tax in Sydney will give you the answer.
How do you 'read' an US individual tax return for Australian tax purposes? This is the question we asked Seth Hertz of Expat US Tax.
US v Australian tax for individuals - how is US tax different from Australian tax and vice versa? Here is Seth Hertz with some insights.
US citizens living in Australia are taxed on their worldwide income in Australia but also in the US. Here is Seth Hertz of Expat US Tax with more.
What are the three biggest issues around international tax at the moment? Here is Bob Deutsch with some thoughts.
The Foreign Investment Review Board is to protect Australia's national interests. Here is Simon Dorevitch with more.
Since the 2019 Harding case a permanent place of abode no longer needs to be a specific dwelling. Here is Andrew Henshaw of Velocity Legal with more.
Tax havens start talking to the ATO thanks to the new Common Reporting Standards. Ben Sewell of Sewell & Kettle provides a helpful overview.
The Panama Papers were the scandal the world had to have. In this episode Ben Sewell of Sewell & Kettle in Sydney tells us how it happened and what it meant.
How do you set up shop in an offshore tax haven? Ben Sewell of Sewell & Kettle shows you what it takes and a few more things along the way.
How does the US tax system affect the Australian spouse of a US citizen or Green card holder? Jane Bruno of Bruno American Tax Services will give you the answer.
As a US citizen or Greencard holder, the US will tax your worldwide income even while you live in Australia. Jane Bruno Bruno American Tax Services will give you the details.
We have all heard of Bywater, but what actually happened? How was it set up? And how did the ATO find out about it? Here is Robert Campbell of McLeod Campbell & Associates with more.
Something as fundamental as tax residency should result in a clear answer. But it doesn't. Too hard as Clint Harding of Arnold Block Leibler will argue.
Tax residency is the gateway to the Australian taxation system. Robert Campbell of McLeod Campbell will walk you the ground rules around residency.
Tax Talks is Australia’s tax news podcast for tax professionals. Informative, entertaining and free.
Liability Limited by a scheme under the Professional Standards Legislations