This presentation covers:
- Quarantining the profits of the foreign entity at the foreign corporate tax rate (subject to Australia's CFC rules and transfer pricing regime)
- Accessing the dividend exemption under Subdivision 768-A ITAA 1997
- Accessing CGT reductions under Subdivision 768-G ITAA 1997
- Application of s23AH branch exemption to foreign' subsidiaries
- Determining the members of a tax consolidated group and whether foreign subsidiary members may be considered part of an Australian group depending on where decisions are made
- Whether the CFC rules apply to the entity and implications for common foreign hybrid' flow through entities
- Application of Australia's double tax treaties.