UNSW Handbook Course - International Tax: Anti-Avoidance

International Tax: Anti-Avoidance - ATAX0308


	Faculty: Faculty of Law
	School: Australian School of Taxation
	Course Outline: See below
	Campus: ATAX Campus
	Career: Postgraduate
	Units of Credit: 6
	EFTSL: 0.12500 (more info)
	Indicative Contact Hours per Week: 0
	Enrolment Requirements:
	Restricted to students enrolled in Program 5540
	Excluded: ATAX0408, ATAX0508
	Fee Band: 3 (more info)
	Further Information: See Class Timetable

Description

International Taxation comprises a complex body of learning which is relevant to any cross border event whether that be in the form of cross border investment or cross border movement of people. This course exposes participants to the main aspects of the law which are relevant specifically to preventing avoidance of taxpayer obligations in respect of Australia's international taxation jurisdiction. The areas covered need to be clearly understood by anyone dealing with cross border income flows in order to avoid inadvertently falling into an unexpected trap created by these provisions.

Recommended Prior Knowledge

ATAX0305 Taxation of Trusts
ATAX0311 Taxation of Capital Gains
ATAX0320 Principles of Australian International Taxation

Students without this prior knowledge may find that they need to take steps to ensure adequate understanding of the related area. Note: as some area of tax law are interrelated in some courses, we recommend that students either have prior knowledge of the related area or study another course in that area concurrently.

Course Objectives

To familiarise students with the basics of the attribution (Controlled Foreign Corporations, Transferor Trusts and Foreign Investment Funds), thin capitalisation, and transfer pricing measures
To provide a detailed study of the attribution rules, focusing on concepts of control, active income and methods of attribution
To provide a brief review of international comparisons of anti-avoidance measures

Main Topics

Taxation of deferred foreign income - an overview
CFC's, control and attributable taxpayers
Active income test
CFC-attributable income
Dividends, exemptions and foreign tax credits
Second tier CFC provisions and deemed dividends
Non resident trusts (excluding FIFs)
Foreign investment funds
Other anti avoidance measures
Record keeping requirements

Assessment

2 Assignments
1 Exam

Course Texts

Information regarding the Atax Textbook Lists for Semester 1 will be available on the UNSW Bookshop website from 1 February.

Information regarding the Atax Textbook Lists for Semester 2 will be available on the UNSW Bookshop website from 1 July.

Order from UNSW Bookshop:
http://www.bookshop.unsw.edu.au/atax.html

URL for this page:

© The University of New South Wales (CRICOS Provider No.: 00098G), 2004-2011. The information contained in this Handbook is indicative only. While every effort is made to keep this information up-to-date, the University reserves the right to discontinue or vary arrangements, programs and courses at any time without notice and at its discretion. While the University will try to avoid or minimise any inconvenience, changes may also be made to programs, courses and staff after enrolment. The University may also set limits on the number of students in a course.