International tax
Mr Wayne Gumley
12 points
* 3 hours per week and private research
* Caulfield
Objectives On completion of this subject students should, at an advanced level and in relation to a range of typical transactions in Australia and overseas involving residents and non-residents, be able to identify and analyse the taxation issues which arise from such transactions under the Income Tax Assessment Act 1936 (Cth), the Income Tax (International Agreements) Act 1953 (Cth) and related legislation; conduct research into, and give an informed view on the likely development of the law in relation to, the area of international taxation.
Synopsis Topics include residence; source; withholding taxes; foreign tax credit system; tax havens; double tax treaties; thin capitalisation; foreign income exemptions; foreign source dividends; transferor trusts; controlled foreign companies; foreign investment funds.
Assessment Research project (5000-7000 words): 50%
* Examination
(open-book 3 hours): 50%
Prescribed texts
Income Tax Assessment Act 1936 (Cth)
Income Tax (International Agreements Act 1953 (Cth)
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