Controlled foreign companies

International tax: Treatment of Income Pursuant to s 324

Associates: A partnership as an associate of a natural person

Controlled foreign companies: amalgamation of two controlled foreign companies - transfer of assets

Controlled foreign companies: amalgamation of two controlled foreign companies - cancellation of shares

Controlled foreign companies: financial intermediary business

Controlled foreign companies: financial intermediary business - foreign exchange gains on repayment or other disposal of loans

Controlled foreign companies: financial intermediary business - currency forward agreements and currency swap agreements hedging foreign currency transactions

Income tax: how is double taxation avoided in the following situations where a Controlled Foreign Company (CFC) pays a dividend to an attributable taxpayer:(a) Out of income or profits derived by the CFC during a statutory accounting period that are subject to attribution and paid after the end of the CFC's statutory accounting period but before the end of the attributable taxpayer's year of income? (b) Out of income or profits derived by the CFC during a statutory accounting period that are subject to attribution and paid both before the end of the CFC's statutory accounting period and the attributable taxpayer's year of income?

Income tax: can a dividend, or part of a dividend, be non-assessable non-exempt income under both section 23AJ and section 23AI of the Income Tax Assessment Act 1936?

Income tax: in the definition of 'financial intermediary business' what is meant by 'a business whose income is principally derived from the lending of money'?

Income tax: foreign income: how are elections to be made by a controlled foreign company (CFC)?

Income tax: foreign income: does a controlled foreign company (CFC) which conducts its business on a cyclical basis satisfy the active income test?

Income tax: foreign income - can 'trading stock' and 'other assets used solely in carrying on a business' come within the definition of 'tainted asset' in section 317?

Income tax: insurance: where an Australian life assurance company has directed its overseas representatives to purchase and dispose of overseas investments on its behalf, is the resulting profit foreign income for the purposes of the former section 112B of the Income Tax Assesment Act 1936 ?

Income tax: foreign income: is foreign tax payable by a controlled foreign entity (CFE) under an accruals tax law of a broad-exemption listed country within the meaning of section 456A if, under the tax law of the country, no tax is required to be paid?

Income tax: foreign income: are income or profits which are assessable in a listed country considered to be subject to tax in the listed country within the meaning of section 324 if, under the tax law of that country, no tax is required to be paid?