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Double Tax on U.S sourced Capital Gains

Posted in Australia, Peter Harper | Posted on Oct 8, 2019

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

Subpart F Income

Posted in Quick Guides, Tax Questions | Posted on May 24, 2022

What is Subpart F Income? It relates to international tax and is income earned within a Controlled Foreign Corporation (CFC) that will be... Read more

Subpart F Income: The Briefer

Posted in Tax Questions, Uncategorized | Posted on Oct 3, 2019

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

What does ‘two-up’ have in common with selling Australian real estate while living in the US?

Posted in Australia, Peter Harper | Posted on Oct 1, 2019

I am often asked how can a capital gain associated with your main residence that is tax-free in Australia be taxable in the... Read more

So You Own a CFC, What Now?

Posted in Uncategorized | Posted on Sep 13, 2019

In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we analyze... Read more

Stage Five Clinger: How the TCJA Latches onto Unassuming Foreign Persons through Constructive Ownership

Posted in Tax/Estate Planning & More | Posted on Sep 13, 2019

In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we discuss... Read more

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