Advanced International Tax

Subject 730-658 (2009)

Note: This is an archived Handbook entry from 2009. Search for this in the current handbook

Credit Points:
Level: Graduate/Postgraduate
Dates & Locations: For information about these dates, click here.
Time Commitment: Contact Hours: 24 - 26 contact hours per subject.
Total Time Commitment: The time commitment for this subject depends on the candidates background and experience.
Prerequisites: N.A.
Corequisites: N.A.
Recommended Background Knowledge: None
Non Allowed Subjects: None
Core Participation Requirements: N.A.
Subject Overview:

Objectives:

This subject aims to provide an up-to-date account of the taxation of Australian residents in respect of their interest in foreign entities under the controlled foreign company, foreign investment fund and transferor trust regimes. The subject will critically examine the policy underlying the provisions and undertake a comprehensive review of the detail of the rules. Students will also evaluate whether the rules effectively achieve their policy objectives, whether they are susceptible to tax planning and their effects on compliance.

 


Syllabus:

Principal topics will include:

  • Introduction and background: History and policy of Australia’s taxation of residents in respect of their interests in foreign entities
  • Controlled Foreign Companies: Control/substantial shareholder rules, designated jurisdictions, active income test, calculation of attributable income, taxation of dividends, attribution accounts and other records
  • Foreign Trusts: Overview/general principles, foreign discretionary trusts
  • Foreign Investment Funds: Overview/exemptions, calculation of FIF income, distributions, attribution accounts and other records
  • Interaction among the Offshore Regimes.
Assessment:
  • Seminar assignment (30%)
  • Take-home examination (70%) (13–16 November)

 
Prescribed Texts: Core subject materials will be provided free of charge to all students. Some subjects require further texts to be purchased. Please visit the subject homepage on the Melbourne Law Masters website by following the link at the bottom of this subject entry.
Breadth Options:

This subject is not available as a breadth subject.
Fees Information: Subject EFTSL, Level, Discipline & Census Date
Generic Skills: Please see the Subject Objectives for this information.
Links to further information: 730-658Advanced International TaxMelbourne Law Masters, postgraduate law, post-graduate law, graduate law2009P

Objectives:

This subject aims to provide an up-to-date account of the taxation of Australian residents in respect of their interest in foreign entities under the controlled foreign company, foreign investment fund and transferor trust regimes. The subject will critically examine the policy underlying the provisions and undertake a comprehensive review of the detail of the rules. Students will also evaluate whether the rules effectively achieve their policy objectives, whether they are susceptible to tax planning and their effects on compliance.

 


Syllabus:

Principal topics will include:

  • Introduction and background: History and policy of Australia’s taxation of residents in respect of their interests in foreign entities
  • Controlled Foreign Companies: Control/substantial shareholder rules, designated jurisdictions, active income test, calculation of attributable income, taxation of dividends, attribution accounts and other records
  • Foreign Trusts: Overview/general principles, foreign discretionary trusts
  • Foreign Investment Funds: Overview/exemptions, calculation of FIF income, distributions, attribution accounts and other records
  • Interaction among the Offshore Regimes.
  • Seminar assignment (30%)
  • Take-home examination (70%) (13–16 November)

 

N.A. N.A.24 - 26 contact hours per subject.Core subject materials will be provided free of charge to all students. Some subjects require further texts to be purchased. Please visit the subject homepage on the Melbourne Law Masters website by following the link at the bottom of this subject entry.Please see the Subject Objectives for this information.The time commitment for this subject depends on the candidates background and experience.N.A.Please see the subject homepage on the Melbourne Law Masters website for up to date timetable information.LawLawYNNNParkvillePARKVILLEFor the latest information on this subject, please visit: http://www.masters.law.unimelb.edu.au/subject/730658730-6582

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