What to do before you start establishing your entity in the U.S?

Expanding business operations into the U.S. can be a lucrative opportunity to grow business if the structural decisions are made at the right time by...

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CGT Main residence exemption removed for Foreign residents

  The Australian Senate passed the Treasury Laws Amendment (Reducing Pressure on Housing Affordability Measures) Bill 2019 overnight. If you are a “foreign resident” for...

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Reporting compliance for foreign trusts in the U.S.

In our previous blog for our U.S – India channel, Foreign Trusts in the U.S., we discussed about the treatment of foreign trusts as grantor...

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The U.S. GILTI rules do not correspond to Australia’s CFC attribution rules for the purposes of the Australian hybrid mismatch rules: TD 2019/D12

The ATO has just released draft Tax Determination TD 2019/D12 in which it confirms that section 951A of the U.S. Internal Revenue Code (IRC) is...

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Hierarchy of the CFC and PFIC Code Sections

If you look back to our definition of a PFIC, it appears as though a foreign company can concurrently be a CFC and a PFIC....

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Should You File a Form 5471 or Form 5472?

If your business is expanding into the U.S. then you will need to determine exactly which forms to file and how much income to report...

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FBCI Exclusion One: The De Minimus Rule

In our earlier blog post, Digging Deeper into Subpart F Income: Foreign Base Company Income, we discussed how FBCI must be included as Supbart F...

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Double Tax on U.S sourced Capital Gains

The ATO have successfully argued in the Federal Court of Australia in the case of Burton v Commissioner of Taxation [2019] FCAFC 141 that only...

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Digging Deeper into Subpart F Income: Foreign Base Company Income

In our previous blog, Subpart F Income: The Briefer, we introduced Subpart F Income and how U.S. Shareholders of controlled foreign corporations must pay U.S....

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Subpart F Income: The Briefer

As mentioned in the previous blog, So You Own a CFC, What Now?, we introduced the fact that controlled foreign corporations must pay U.S. tax...

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