This presentation focusses on three key areas arising from the proposed amendments in Tax Laws Amendment (2007 Measures No. 4) Bill. First, it examines the impact of the proposed removal of the foreign tax credit quarantining rules, considers the application of the transitional provisions that apply for taxpayers seeking to utilise existing carry forward tax credits, and highlights continuing issues for taxpayers seeking to utilise foreign tax credits. The presentation also touches on the interaction of the proposed foreign tax credit rules with the 'foreign hybrid' regime. Second, the presentation focusses on the impact of the proposed removal of the foreign loss quarantining rules, and the operation of the transitional provisions to convert existing foreign losses into tax losses. Finally, there is a discussion about the introduction of a Controlled Foreign Company calculation election for certain Foreign Investment Funds, including its interaction of the FIF rules with the proposed foreign tax credit rules.
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