General rules

A cell in a protected cell company formed in Guernsey and the controlled foreign company measures

Definition of public company: company controlled by a Government or public body - meaning of 'Government'

Definition of 'public company': company controlled by a Government - tracing an interest held through a chain of subsidiaries

Income tax: does the notional assessable income of a controlled foreign company include an amount deemed to be a dividend under section 47A of the Income Tax Assessment Act 1936?

Income tax: can the attribution regime relating to controlled foreign companies apply to an Australian entity that is a member of a foreign company limited by guarantee?

Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to a scheme designed to convert otherwise assessable interest income into non-assessable non-exempt dividends?

Income tax: is section 951A of the US Internal Revenue Code a provision of a law of a foreign country that corresponds to sections 456 or 457 of the Income Tax Assessment Act 1936 for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997 ?

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: 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?

Income tax: foreign income: is a lump sum payment received by a controlled foreign company (CFC), as consideration for the assignment of an interest stream, passive income for the purposes of Part X of the Income Tax Assessment Act 1936 (the Act)?

Income tax: meaning of 'Arm's Length' for the purpose of subsection 47A(7) of the Income Tax Assessment Act 1936 (ITAA 1936) dividend deeming provisions

Income tax: whether the holding of pre-emptive rights, call options and put options constitute a contingent entitlement to acquire for controlled foreign company (CFC) purposes

Income tax: application of the transferor trust and controlled foreign company measures where property or services are transferred to a non-resident company in which a non-resident trustee has a direct or indirect ownership interest