International Tax

Our firm’s expertise in income tax also covers the taxation of international transactions. In particular for business tax purposes we are able to advise on:

• Controlled Foreign Companies (“CFC”) and Foreign Investment Funds (“FIF”) issues for companies and trusts which are located overseas but controlled by Australian Residents;
• Foreign trusts with Australian beneficiar ies;
• Thin capitalisation;
• Foreign tax credit;
• Withholding tax; and
• Double tax agreement issues.

In the personal tax sphere our firm is able to provide advice for Australian expatriates and for persons wishing to immigrate to Australia. Taxation issues which may arise for such persons include:

• Residency status for tax purposes;
• The taxation of income earned overseas;
• The capital gains tax implications of becoming or losing one’s Australian tax residence; and
• The status of superannuation which is accumulated in an Australian superannuation fund and which is left behind when an individual emigrates from Australia