Most comprehensive international taxation notes

Description

Topic 1. Jurisdiction to tax – residence and source (a) Overview of jurisdiction & introduction to tax treaties (b) Residence (c) Source and BEPS Topic 2. Taxation of foreign source income of residents (a) Taxation of controlled foreign companies (b) Foreign branch income exemption (c) Taxation of foreign trusts (d) Foreign capital gains and dividends exemption (e) Foreign income tax offset Topic 3. Transfer pricing Topic 4. Australian taxation of non-residents (a) Capital gains tax (b) Conduit foreign income (c) Dividend, interest, and royalty withholding tax (d) Taxation of managed investment vehicles