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.
Foreign trusts are not an issue per se. Nor are resident trusts. It really depends. But if you do have a foreign trust, watch out for s99B ITAA 1936. That is a really dangerous one.
You have seven options to qualify for the simplified transfer pricing record keeping as outlined in PCG 2017/2.
How to hire offshore staff - only 2 steps but there is a lot in there.
How to find your offshore staff - nine steps to find who you need. From advertising to shortlisting and interview.
What is it like to work in a labour hire agency in the Philippines? Get an insider view on moonlighting and staff poaching.
Charitha Wasala tells you how he set up his own direct offshore team in Sri Lanka and manages his teams - directly without an agency sitting between him and his people.
Offshore labour hire has become a very popular solution. Listen to three Australian accountants about their experiences.
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.
A resident director usually fulfills just one specific role. And that is to meet the ASIC requirement that one director of a private Australian company must reside in Australia.
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?
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.
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.
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.
In this episode Simon Dorevitch of A & A Tax Legal Consulting in Melbourne will tell you how the so-called Netflix tax actually works.
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.
When is the export of services GST-free? Here is Simon Dorevitch of A & A Tax Legal Consulting in Melbourne with the answer.
Only services connected with ITZ (indirect tax zone) can possibly be subject to GST as Simon Dorevitch of A & A Tax Legal Consulting will tell you.
Incoterms are pre-defined commercial terms. Simon Dorevitch of A & A Tax Legal Consulting will tell you what they mean.
When is the export of goods GST-free? Simon Dorevitch of A & A Tax Legal Consulting will give you a comprehensive answer.
Without a connection to the ITZ, there is no taxable supply. Simon Dorevitch of A & A Tax Legal Consulting will tell you more.
Australia ratified the OECD's Multilateral Instrument in September 2018. Simon Dorevitch of A & A Tax Legal Consulting will tell you what happens next.
The multilateral instrument is to stop base erosion and profit shifting. Here is Simon Dorevitch of A & A Tax Legal Consulting with more.
Multinational base erosion and profit shifting harms Australia through lost tax revenue. Here is Simon Dorevitch of A & A Tax Legal Consulting with more.
Offshoring has a negative connotation. But it doesn't have to be this way. Mike O'Hagan of Mike's Buiness Tours will show you the options you have.
Tax havens start talking to the ATO thanks to the new Common Reporting Standards. Ben Sewell of Sewell & Kettle provides a helpful overview.
If you could change one thing about the Australian tax system, what would it be and how? Robert Deutsch of The Tax institute asked that question.
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.
Do you offshore SMSF work or not? Chloe Ward of Intello will tell you how they turned staying in Australia into an advantage.
Tax Talks is Australia’s tax news podcast for tax professionals. Informative, entertaining and free.
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