With more and more SME businesses operating globally and more of us spending periods of our lives living and working abroad, trusts are increasingly impacted by international issues.
The Noosa Tax Intensive, now in its 25th year, this year features a number of sessions that address the issues surrounding trusts and the international issues that arise when they are part of a cross-border structure.
Here we take closer look at three of these sessions and speak with Deloitte's Hannah Soh CTA, who will coordinate the ‘Trusts and international tax issues’ workshop on day one of the Intensive, and William Buck's Craig Barry CTA, one of the workshop’s leaders, about what to expect at the event.
Following the opening keynote address from Clayton Utz's Allan Blaikie CTA, titled ‘Looking back over 25 years of the Noosa Tax Intensive’, Finlaysons' Michael Butler CTA will presents the session called ‘Trusts – vesting, splitting, cloning and other matters’.
With a number of historical trusts now reaching their vesting dates, many trust controllers are concerned about ensuring orderly succession of the trust assets. Michael’s session will look at the issues around vesting, the implications of the ATO’s recent views, splitting and cloning trusts, and other issues.
Michael’s session will be followed by Pitcher Partners' Denise Honey CTA on ‘International tax issues for privately held groups’.
|Craig Barry CTA (William Buck)|
Denise will cover the international tax issues that arise when trusts are part of a cross-border structure. She will look at tax residency for trusts in the post-Bywater era, issues for income and gains derived by non-resident trusts, the tax issues arising for Australian tax resident trusts with cross-border activities or beneficiaries, and considerations in structuring offshore business operations.
These two plenary sessions set the scene for the workshop coordinated by Hannah and led by Craig, along with Emma Woolley CTA (Hall & Wilcox Lawyers), Linda Farmer CTA (Grant Thornton), George Psarrakos CTA (Mutual Trust), Mariana Von Lucken CTA (HLB Mann Judd) and Paul Lyon ATI (EY).
Hannah says delegates can expect "a deep dive into the issues presented in the two sessions from Michael and Denise, with a focus on real-life examples that will demonstrate the concepts involved."
Craig added that ‘the aim is to have delegates engage in a robust discussion regarding SME tax matters in respect of trusts and international tax issues.’
The workshop uses a number of case studies, based on real-life examples, that will cover vesting dates, splitting and cloning, family trust succession planning, tax residency for trusts, and what happens when an individual ceases Australian residency.
Craig’s view was that "the workshop-style approach should hopefully allow delegates to better identify and deal with some of the more complex client issues out there."
Closing day one, we have representatives from the ATO offering the ATO’s views on the key topics raised during the day’s earlier plenary sessions in an interactive discussion format.
The 25th Noosa Tax Intensive will take place on 16-17 November 2017 at the Sofitel Noosa Pacific Resort.
You can find out more about these sessions and the rest of the program for this special Silver Anniversary edition on our website.