Advising Clients Setting Up In The USA (Part 2)
22nd Nov 2024
Matthew Marcarian
Setting Up A US Corporation In Part 1 of this article we discussed Controlled Foreign Company (CFC) under Part X if ITAA 1936 either because of the strict control test or the deemed control...
Advising Clients Setting Up In The USA (Part 1)
22nd Nov 2024
Matthew Marcarian
Setting Up A US Limited Liability Company (LLC) The United States is a key market for Australian businesses seeking to expand overseas The breadth and depth of economic opportunities will...
Loans From Foreign Companies: Taxation Implications And Considerations For Accountants
16th Sep 2024
Matthew Marcarian
The global nature of business transactions often involves loans between Australian entities and foreign companies While these transactions can facilitate growth and expansion, they also come with...
Exempt Dividend Income From Overseas Subsidiaries
26th Jun 2024
Matthew Marcarian
It is crucial for tax accountants navigating the complexities of international tax law for SME clients to have a good understanding of the exemption for foreign equity distributions - or what used to...
Personal Tax Residency – A Reform Proposal
30th Apr 2024
Matthew Marcarian
Where Are We At Now In the 2021–22 Federal Budget, the Coalition announced that a new “modernised framework” for Australia’s residency laws would be introduced It was to be based on a...
The Importance Of Correctly Disclosing International Related Party Dealings In Your Client’s Tax Return
26th Mar 2024
Matthew Marcarian
Any Australian company that has an interest in a Controlled Foreign Company (CFC) will be required to disclose the relevant information in their tax return This may include reporting attributed...
How To Identify If Your Client Has A Controlled Foreign Company (CFC)
13th Dec 2023
Matthew Marcarian
A Controlled Foreign Company (CFC) is essentially a non-resident company that is controlled by Australian resident shareholders or a small group For a typical Australian SME, a CFC will usually be...
Assessing Corporate Tax Residency For Your Client’s Company
12th Mar 2023
Matthew Marcarian
When your client expands their business overseas there is one foundational question you need to ask: “Is the client’s overseas company a tax resident in Australia” This foundational question...