Financial Reporting
When operating a multi-family office, one of the...
Family Office Vlog Series: Ep....
In our 12th episode of the Family Office...
Family Office Vlog Series: Ep....
Asena CEO Peter Harper comments on how family...
Family Office Real Estate
Family Office Real Estate In the world of...
Family Office Vlog Series: Ep....
In our 10th episode of the Family Office...
Woodpoint Letter (Q1 2020): Correction or recession?
Market volatility reminds investors to understand risk In our last investment letter, we examined the macro environment moving into 2020 and discussed key...Read more
Restructuring your US operations – Part 3: Anti-avoidance rules in the Internal Revenue Code
Where a corporate reorganization results in a transfer of property to a foreign corporation (such as an Australian registered company), the normal nonrecognition...Read more
CGT and foreign resident beneficiaries: TD 2019/D6 and TD 2019/D7
The Australian Taxation Office recently released draft Taxation Determinations TD 2019/D6 and TD 2019/D7. The combined effect of the draft Determinations is that...Read more
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...Read more
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...Read more