LAWS6129 - Taxation of Controlled Foreign Companies, Foreign Investment Funds & Transferor Trusts

Taxation of CFCs, FIFs and Transferor Trusts is a detailed study of Australia's anti-deferral rules. The unit examines the taxation of Australian residents with interests in foreign entities, particularly foreign companies, trusts and partnerships, and the application of the CFC and transferor trust regimes, the proposed new Foreign Accumulation Fund ("FAF") regime, and the recently repealed FIF and deemed present entitlement rules to those interests.

The unit focuses particularly on the design differences between those rules, and their interactions and reconciliations. The unit will critically examine the policy underlying the rules and evaluate whether they effectively achieve their policy objectives, whether they are susceptible to tax planning and what their effects are on compliance, including compliance costs. There will be consideration of the ongoing reform of the rules. Students should gain a detailed understanding of the design and application of Australia's antideferral rules.

Session

Semester 2 Intensive
4-6 & 9, 10 September 2013

The timetable is subject to frequent changes. Please refer to the latest version of the Postgraduate Timetable.

Assessment

• 1 x 3,000 Word Assignment (30%)
• 1 x Two-Hour Exam (70%)

Legal Professional Development (LPD)

You can credit this unit towards Legal Professional Development (LPD). Units of study that are part of Sydney Law School’s Postgraduate Program meet the necessary Mandatory Continuing Legal Education (MCLE) of the Law Society of New South Wales and the Continuing Professional Development (CPD) requirements of the New South Wales Bar Association. You may complete this unit of study by enrolling on a non-degree basis or on an audit basis only with no assessment via Single Unit Enrolment.

Courses this unit is available in

Master of Laws | Graduate Diploma in Law | Master of Global Law | Master of Business Law | Master of International Taxation | Master of Taxation | Graduate Diploma in Taxation