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Subject outline

Australia Taxation - Advanced is divided into 10 Modules

Module 1 - Tax theory and tax policy and reform

Module 2 - Trusts and trust distributions

Module 3 - Superannuation

Module 4 - Companies and company distributions

Module 5 - Consolidations

Module 6 - Complex business structures

Module 7 - Corporate financing

Module 8 - International transactions and cross-border tax issues

Module 9 - Advanced GST issues

Module 10 - Anti-avoidance regimes

The brief content of these modules are as follows:

Module 1 - Tax theory and tax policy and reform

Part A: Tax theory

• The principles of taxation and tax theory relevant to a tax regime

• Weighting the tax policy criteria

• Political considerations

Part B: Tax policy

• Australian tax reviews

• Australia’s tax system

• Income and capital taxes

• Domestic consumption and production taxes

• Tax-related social and economic policies

• International tax

• The effect of court decisions on tax law reform

Module 2 - Trusts and trust distributions

Part A: Income and expenditure

• Taxation of trusts and trust distributions

• Income versus net income of the trust estate

• Determining net income of the trust and tax implications on distribution

• Financing trust payments of capital or income distributions—deductibility of interest

Part B: Beneficiaries and distributions

• Making distributions from the trust to beneficiaries

• Presently entitled

• Distributions to minors

• Corporate beneficiaries

• Deemed dividends

• Unpaid present entitlements

• Streaming of trust income

• Rateable reduction

• Deceased estates and testamentary trusts

Part C: Capital gains tax-specific rules

• Capital gains tax ‘E’ events

• Capital gains tax event E4 in detail

• Tax consequences of the vesting or resettlement of a trust

• Trusts and the small business capital gains tax concessions

Part D: Carry-forward trust losses

• Distinction between fixed and non-fixed trusts

• Trust loss tests for fixed and non-fixed trusts

• Family trusts Error! Bookmark not defined.

Module 3 - Superannuation

Part A: Types of superannuation funds and compliance requirements

• Legal basis for superannuation

• Complying versus non-complying funds

• Defined benefit versus accumulation funds

• Specific types of superannuation funds

• Taxed and untaxed funds

• MySuper funds

• Compliance requirements for superannuation funds

Part B: Taxation of contributions

• Concessional contributions

• Non-concessional contributions

• Contribution age limits

Part C: Taxation within the superannuation fund

• Contributions received by the superannuation fund

• Accumulation and income stream phases

• Taxation of superannuation fund investment earnings

• Deductions available to accumulation funds

• Taxation consequences of becoming a non-complying fund

Part D: Taxation of superannuation benefits

• Conditions of release and authorised payments

• Taxation of lump sums

• Taxation of income streams

• Superannuation death benefits

• Maximising tax-free components

Part E: Self-managed superannuation funds

• Establishing a self-managed superannuation fund

• Trustee responsibilities

• Taxation of self-managed superannuation funds

• Rules affecting self-managed superannuation funds

• Consequences of breaching the rules

Module 4 - Companies and company distributions

Part A: Taxation of companies

• Introduction

• Calculation of taxable income

• Company tax rates

• Tax offsets

• Tax losses

Part B: Specific incentives and concessions

• R&D tax incentive

• Early stage innovation companies

Part C: Companies and CGT

• Introduction

• Small business CGT concessions

• Corporate restructure relief

Part D: Advanced imputation issues

• Dividend imputation system

• Integrity rules

• Franking accounts

• Franking deficit tax

• Franking account tax return

• Effect of receiving a distribution

Part E: Deemed dividends

• Introduction

• Division 7A

• Capital streaming arrangements

• Bonus share issues

• Redeemable preference shares

• Excessive remuneration

• Share buy-backs

• Distributions by liquidators

Module 5 - Consolidations

Part A: Eligibility to consolidate

• Consolidatable group

• Head company

• Subsidiary member

• Factors affecting the decision to consolidate

• Comparison to accounting consolidation rules

• Multiple entry consolidated group

Part B: Key consolidation rules

• Single entity rule

• Entry history rule

• Exit history rule

• Consolidated group’s tax compliance

• Tax sharing agreements

• Pay-As-You-Go instalment payments

• Recognising franking credits and foreign income tax offsets

• Interaction of single entity rules with other income tax provisions

Part C: Joining a consolidated group

• Calculating the allocable cost amount of the joining member

• Identifying assets eligible for allocation of allocable cost amount

• Allocating the allocable cost amount over a joining member’s assets

• Capital gains tax events on entry

• Modification of the allocable cost amount tax cost setting rules

Part D: Transfer and utilisation of losses

• Determining losses to be transferred

• Utilising transferred losses

• Modification of loss transfer and utilisation for a multiple entry consolidated group

Part E: Exiting a consolidated group

• Resetting costs of membership interests in a subsidiary

• Calculating the allocable cost amount of the leaving entity

Module 6 - Complex business structures

Part A: Assessment of group business structure

• Categories of business entity

• Commercial factors in selecting an entity

• Tax factors to consider when selecting entity

• Capital gains tax rollover relief

• Combination of multiple group entities

Part B: Multi-entity combination involving companies

• Limitations of a company as sole entity

• Licensing intellectual property to a related entity

• Provision of administrative services by a service trust

Part C: Multi-entity combination involving partnerships

• Limitations of a partnership as sole entity

• Partnership sets up a property-holding unit trust

• Partnership of discretionary trusts with corporate trustee and company manager

• Corporate limited partnerships

Part D: Multi-entity combination involving trusts

• Limitations of a trust as sole entity

• Unrelated discretionary trusts set up a subsidiary unit trust

• Distributions to discretionary corporate beneficiaries

• Interaction with self-managed superannuation funds

Part E: Assessment of tax risks

• Personal services income

• Part IVA

Module 7 - Corporate financing

Part A: Debt and equity rules

• The test that identifies a debt interest

• Test that determines whether an interest is an equity interest

• Non-share equity interests and non-share capital account

• Tiebreaker rule

Part B: Value shifting

• Entity interest direct value shifting rules

• Created rights direct value shifting rules

• Method used to make a reduction

• Indirect shifting rules

Part C: Thin capitalisation

• Thinly capitalised entities

• Types of entities and control

• Non-authorised deposit-taking institution outward investing entities

• Non-authorised deposit-taking institution inward investing entities

• Authorised deposit-taking institution entities

Part D: Financial arrangements and financial instruments

• Taxation of financial arrangements regime

• Outside taxation of financial arrangements regime

• Asset and project financing arrangements

Module 8 - International transactions and cross-border tax issues

Part A: Foreign exchange gains and losses

• Conversion of foreign currency

• Functional currency

• Taxation treatment of foreign exchange gains and losses

Part B: Transfer Pricing

• Legislative framework

• The arm’s length principle

• Documentation and reporting

• Key compliance issues

• Applying the arm’s length principle

• Accepted arm’s length methodologies

Part C: Conduit Foreign Income

• Background

• The meaning of conduit foreign income

• Distribution of conduit foreign income

Part D: Foreign income attribution

• Background

• Controlled foreign companies

• Transferor trusts

Part E: Foreign income tax offsets

• Entitlement to foreign income tax offset

• Calculation of foreign income tax offset

Part F: Double taxation agreements

• Background

• Other anti-avoidance issues

• Structure of double tax agreements

Module 9 - Advanced GST issues

Part A: GST Overview

• Applying relevant GST rules in complex transactions

Part B: Input tax credits relating to a financial supply

• Financial supplies

• Apportionment of financial supplies

• Creditable acquisitions

Part C: Cross-border transactions

• Supplies connected with the indirect tax zone

• Export of goods and services

• Goods imported into the indirect tax zone

• Imports other than goods and real property

Part D: Property and special transactions

• Real property margin scheme

• GST-free supply of a going concern

• Residential and commercial residential property

• Second-hand goods

Part E: Attribution rules

• GST attribution rules

• Adjustment events

Part F: GST anti-avoidance provisions

• General anti-avoidance rules

Module 10 - Anti-avoidance regimes

Part A: The application of the general anti-avoidance provisions of Part IVA

• Tax evasion, avoidance and planning

• The general provisions of Part IVA

• Application to particular transactions and leading cases

• The role of advisers

Part B: The application of the multinational tax avoidance rules

• Schemes that limit a taxable presence in Australia

• Diverted profits tax

Part C: Tax information exchange agreements and other ATO information gathering powers

supporting multinational tax avoidance rules