BTF4280

Taxation of international transactions ( 6 points, SCA Band 3, 0.125 EFTSL)

Leader: Dr Bill Orow

Offered:
Not offered in 2005.

Synopsis: This unit examines the operation of the general residence and souce rules, double taxation agreements, thin capitalisation rules, controlled foreign companies, Foreign Investment Funds, transfer of trusts, and a range of exemptions.

Objectives: Upon completion of this unit, students should be able to: understand the manner in which the taxation system applies to cross border arrangements and transactions; develop a sound knowledge of the statutory and case law as well as administrative rulings of the Australian Taxation Office that relate to the taxation of international transactions and arrangements; apply the relevant principles to specific transactions and arrangements involving foreign nationals; and conduct relevant research of possible new developments in the law relating to the taxation of international transactions. More specifically, this unit examines the operation of the general residence and source rules, double taxation agreements, thin capitalisation rules, controlled foreign companies and a range of exemptions.

Assessment: Option 1: Research assignment (3000 words): 30% + Examination (3 hours, Open book/take home): 70% Option 2: Examination (3 hours, Open book/take home): 100%

Contact Hours: Three hours per week on-campus and/or intensive mode over summer (both 39 hours in total)

Prerequisites: BTX5651

Prohibitions: BTF4480, BTF5590, BTF5280