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14 May 2019 | External Publications | Corporate and Mergers & Acquisitions

Submission on Demergers – TD 2019/D1 – What is a ‘restructuring’

Greenwoods & Herbert Smith Freehills has made a submission on Demergers – TD 2019/D1 – what is a ‘restructuring’ for the purposes of subsection 125-70(1) of the Income Tax Act 1997?

(261 kb)

20 Mar 2019 | External Publications | Corporate and Mergers & Acquisitions

The Inward and International Taxation Review - Ninth Edition

There have been significant recent changes in the global tax landscape as highlighted in the OECD annual report on global tax policy reforms published on 5 September 2018. The report noted the impact of major tax reform in a number of countries, notable in the United States, Argentina and France.

(314 kb)

19 Mar 2019 | External Publications | Financial Services

Banking Tax Update 2019

Consultant Richard Vann presented on FCT v BHP Billiton Limited [2019] FCAFC 4 and Directors Andrew Hirst and Julian Pinson presented on the hybrid mismatch rules, with a focus on examples affecting banks.

(166 kb)

20 Feb 2019 | External Publications | Corporate and Mergers & Acquisitions | Private Equity

Taxing private trusts - a moving target

The Tax Institute of Australia has published a feature article by Cameron Blackwood, Graeme Cooper and Andrew White on taxing private trusts.

(629 kb)

22 Nov 2018 | External Publications

International Comparative Legal Guide to Corporate Tax 2019

Directors Richard Hendriks and Cameron Blackwood have authored the chapter on Australian corporate tax for the 2019 edition of The International Comparative Legal Guide to: Corporate Tax.

International Comparative Legal Guide to: Corporate Tax 2019: Australia (752 kb)

12 Oct 2018 | External Publications | Financial Services

Anti-Hybrids: The Current State of Play

Anti-Hybrids: The Current State of Play is a paper written and presented by Andrew Hirst and Ryan Leslie for The Tax Institute’s Vic 6th Annual Tax Forum. The paper provides an overview of the rules which will take effect from 2019 and provides practical examples of how the rules will affect a range of instruments and structures.

(3538 kb)

04 Jun 2018 | External Publications | Private Wealth

Managing Part IVA

The Tax Institute's Private Business Tax Retreat was held on the Gold Coast from 31 May - 1 June 2018. As part of the Retreat, Greenwoods & Herbert Smith Freehills Director Cameron Blackwood and Senior Associate Chris Aboud presented on managing Part IVA.

The Tax Institute Private Business Tax Retreat - Managing part IVA presentation - Cameron Blackwood and Chris Aboud (444 kb)

29 May 2018 | External Publications | International

Non-residents and CGT - A refresher and an update

The Tax Institute's NSW 11th Annual Tax Forum was held in Sydney from 24 - 25 May 2018. As part of the Forum, Greenwoods & Herbert Smith Freehills Director Cameron Blackwood presented on non-residents and CGT.

The Tax Institute NSW 11th Annual Tax Forum - Non-residents and CGT presentation - Cameron Blackwood May 2018 (964 kb)

22 Nov 2017 | External Publications

International Comparative Legal Guide to Corporate Tax 2018

Greenwoods & Herbert Smith Freehills Directors Adrian O'Shannessy and Tony Frost have again authored the chapter on Australian corporate tax for The International Comparative Legal Guide to: Corporate Tax, published by Global Legal Group Ltd, London.

ICLG Corporate Tax (Australia) 2018 (675 kb)

27 Sep 2017 | External Publications | International

The Inward Investment and International Taxation Review, 7th edition

Directors Tony Frost and Adrian O'Shannessy contributed the Australian chapter to the 7th edition of The Inward Investment and International Taxation Review published in February 2017 by The Law Reviews.

(145 kb)

26 May 2017 | External Publications | Private Wealth

The expanding offshore client

"The Expanding Offshore Client – How Australian Tax Rules Are Taken With You and How to Manage Them" was authored by Director Cameron Blackwood and Senior Associate Chris Aboud and presented by Cameron at The Tax Institute Private Business Tax Retreat in May 2017.

(782 kb)

08 Feb 2017 | External Publications | Financial Services

Branch attribution

Director Julian Pinson, Associate Mary Hu and CBA Tax Manager Jerome Wood authored "Branch attribution" which Julian and Jerome presented at The Tax Institute Financial Services conference in February 2017.

(584 kb)

08 Feb 2017 | External Publications | Financial Services

BEPS and hybrid mismatch arrangements

Andrew Hirst authored "BEPS and hybrid mismatch arrangements" which he presented at The Tax Institute Financial Services conference in February 2017.

(810 kb)

08 Feb 2017 | External Publications | Financial Services

The changing shape of regulatory capital

Tony Frost co-authored and presented "The Changing Shape of Regulatory Capital" with Bob Herbert of Morgan Stanley at The Tax Institute Financial Services conference in February 2017.

(1051 kb)

27 Oct 2016 | External Publications | Energy & Resources | Corporate and Mergers & Acquisitions

The legal meaning of "market value"

Tim Kyle authored and presented "The legal meaning 'market value'" at The Tax Institute's National Resources Tax Conference in October 2016.

(1066 kb)

27 Oct 2016 | External Publications | Financial Services

Financing and tax – what’s new and what to watch out for

Cameron Blackwood authored and presented "Financing and tax – what’s new and what to watch out for" at The Tax Institute's Corporate Tax Masterclass in October 2016.

(789 kb)

27 Oct 2016 | External Publications | Energy & Resources | Corporate and Mergers & Acquisitions

Consolidations – where is it all up to and what does it mean?

Ken Spence and Ryan Leslie co-authored and presented "Consolidations – where is it all up to and what does it mean?" at The Tax Institute's National Resources Tax Conference in October 2016.

(786 kb)

02 Jun 2016 | External Publications

Capital Management Update

Tim Kyle authored and presented "Capital Management Update" at The Tax Institute's NSW Division 9th Annual Tax Forum in June 2016

(558 kb)

02 Jun 2016 | External Publications | Employment & Superannuation | Private Equity

New Employee share scheme rules: SME startups

Cameron Blackwood wrote and presented "New Employee share scheme rules: SME startups" at The Tax Institute NSW 9th Annual Tax Forum on 2 June 2016.

(857 kb)

02 Mar 2016 | External Publications

Justice Graham Hill Memorial Lecture

On 2 March 2016, Special Counsel Ken Spence was honoured to deliver the Justice Graham Hill Memorial Lecture at the The Tax Institute's 2016 National Convention in Melbourne.

(657 kb)

29 Feb 2016 | External Publications | International

The Inward Investment and International Taxation Review, 6th edition

Directors Tony Frost and Adrian O'Shannessy and Senior Associate Ryan Leslie contributed the Australian chapter to the 6th edition of The Inward Investment and International Taxation Review published in February 2016 by The Law Reviews.

(204 kb)

26 Feb 2016 | External Publications | Corporate and Mergers & Acquisitions

Franking credits in takeovers

Toby Eggleston originally published "Franking credits in takeovers" on the Herbert Smith Freehills website.

17 Feb 2016 | External Publications | Financial Services

Source: Where are we now?

Andrew Hirst, Euan Campbell (Assistant Commissioner, ATO) and Adrian Mak (ATO), co-authored and presented "Source: Where are we now?" at The Tax Institute's Financial Services conference in February 2016.

(393 kb)

17 Feb 2016 | External Publications | Financial Services

Thorny issues in Leasing

Chris Colley published and presented "Thorny issues in Leasing" at The Tax Institute's Financial Services conference in February 2016.

(1016 kb)

17 Feb 2016 | External Publications | International | Financial Services

Financial services in a post-BEPS world

Prof Richard Vann published and presented "Financial Services in a Post-BEPS World" at the Tax Institute Financial Services conference in February 2016.

(433 kb)

23 Dec 2015 | External Publications | Energy & Resources

Surgery with Anaesthetics: M&A Taxation

Surgery with Anaesthetics: M&A Taxation is a one-stop guide to tax problems and abnormalities that arise in the course of M&A activity.

(245 kb)

01 Dec 2015 | External Publications

Division 245: The potential income tax cost of a forgiven debt

Tristan Boyd wrote and presented "Division 245: The potential income tax cost of a forgiven debt" at The Tax Institute WA Division meeting on 1 December 2015.

(229 kb)

02 Oct 2015 | External Publications

Draft update to PS LA 2005/24 on Part IVA – are we just expecting too much?

"Draft update to PS LA 2005/24 on Part IVA – are we just expecting too much? " by Tim Kyle and Tim Neilson was originally published in Thomson Reuters Weekly Tax Bulletin 42 - 2/10/15.

01 Oct 2015 | External Publications | Energy & Resources

Innovation in funding - don't forget the tax!

Nick Heggart originally published "Innovation in funding - don't forget the tax" on the Herbert Smith Freehills website.

04 Sep 2015 | External Publications | Corporate and Mergers & Acquisitions | Private Equity

Scrip for scrip amendments: be aware of changes from draft legislation

"Scrip for scrip amendments: be aware of changes from draft legislation " by Toby Eggleston and Cameron Blackwood considers changes to scrip for scrip rules. It was originally published in Thomson Reuters Weekly Tax Bulletin 38 - 4/9/15.

29 May 2015 | External Publications | Private Equity

Tax confusion down under

"Tax confusion down under" by Toby Eggleston considers changes to the taxation of earn-outs. It was originally published on www.privateequitymanager.com in May 2015.

02 Apr 2015 | External Publications

The Law Reviews - The Tax Disputes and Litigation Review (3rd Ed)

Managing Director Tony Frost and Cameron Hanson (Partner, Herbert Smith Freehills) co-authored the chapter on Australia included in The Tax Disputes and Litigation Review, 3rd edition, published by Law Business Research Ltd in March 2015.

(119 kb)

20 Feb 2015 | External Publications

Before you Tie the Knot

Nick Heggart contributed the chapter on tax to Before You Tie the Knot, a text on joint venture law in Australia published by Sydney University in 2015.

18 Feb 2015 | External Publications | Financial Services

Update on Capital Management Issues

Tim Kyle authored and presented "Update on Capital Management Issues" at The Tax Institute's 2015 Financial Services Taxation Conference in February 2015.

(752 kb)

02 Feb 2015 | External Publications

The Inward Investment and International Taxation Review

Directors Tony Frost and Adrian O'Shannessy contributed the Australian chapter to the 5th edition of The Inward Investment and International Taxation Review published in February 2015 by The Law Reviews.

(148 kb)

03 Dec 2014 | External Publications

Getting the Deal Through - Transfer Pricing 2015

This chapter, authored by Managing Director, Tony Frost and Herbert Smith Freehills partner Hugh Paynter canvasses the issues associated with transfer pricing in Australia.

(517 kb)

21 Nov 2014 | External Publications

The difficult debt-equity rules: Clarifying s 974-80

This article was originally published in Thomson Reuters Weekly Tax Bulletin 49 on 21 November 2014.

12 Nov 2014 | External Publications

International Comparative Legal Guide to Corporate Tax

Greenwoods & Herbert Smith Freehills Directors Adrian O'Shannessy and Tony Frost authored this chapter on Australian corporate tax which appears in the 2015 edition of The International Comparative Legal Guide to: Corporate Tax published by Global Legal Group Ltd, London.

(324 kb)

15 Oct 2014 | External Publications | Energy & Resources

Current Issues in M&A

This paper, authored by Nick Heggart, Tristan Boyd and Daniel Taborsky, was presented by Nick Heggart at The Tax Institute's 2014 National Resources Tax Conference in Perth.

(634 kb)

09 Oct 2014 | External Publications

Issues Arising from the Resource Capital Fund Case

This paper was presented by Abdol Mostafavi which he co-authored with Charlotte Brierley to The Tax Institute's International Tax Masterclass. It was subsequently published in The Tax Specialist.

Issues Arising from the Resource Capital Fund Case (411 kb)

09 Oct 2014 | External Publications | Corporate and Mergers & Acquisitions

Tax Consolidation – Practical Issues in the Current Law

Narelle McBride and Ryan Leslie wrote "Tax Consolidation – Practical Issues in the Current Law" for The Tax Institute's Vic 2nd Annual Tax Forum. The paper was presented by Ken Spence and Ryan Leslie at the event on 9 October 2014.

(558 kb)

20 Sep 2014 | External Publications | Real Estate

974-80 and stapled entities

Casey Wakely co-authored and presented "974-80 and stapled entities" for The Tax Institute's (NSW Division) 9th Annual Property Intensive conference held in Sydney on 20 September 2011.

(506 kb)

11 Sep 2014 | External Publications

Practical application of the New Part IVA

On 11 September 2014, Tim Kyle presented this paper to The Tax Institute's Corporate Tax Masterclass. It was subsequently published in The Tax Specialist.

(216 kb)

01 Jun 2014 | External Publications | Corporate and Mergers & Acquisitions

Capital Management - The Tax Specialist - June 2014

In the June 2014 issue of The Tax Specialist, Richard Hendriks and Cameron Blackwood provide an update on the key Australian income tax issues and ATO practice associated with corporate capital management initiatives.

(590 kb)

21 Feb 2014 | External Publications | Financial Services

Offshore Banking Units

Tony Frost, Craig Marston and CBA's Ultan Mac Donald authored "Offshore Banking Units" for The Tax Institute's 2014 Financial Services Taxation Conference. The paper was presented by Tony Frost and Ultan Mac Donald at the event in February 2014.

(1189 kb)

01 Feb 2014 | External Publications

The Law Reviews - The Tax Disputes and Litigation Review

Managing Director Tony Frost and Cameron Hanson (Partner, Herbert Smith Freehills) co-authored the chapter on Australia included in The Tax Disputes and Litigation Review, 2nd edition, published by Law Business Research Ltd in February 2014.

The Law Reviews - The Tax Disputes and Litigation Review (732 kb)

14 Nov 2013 | External Publications

Tax consolidations - where are we at?

Narelle McBride wrote and presented "Tax consolidations – where are we at?" for The Tax Institute's Corporate Tax Conference (Western Australian Division) held in Perth on 14 November 2013.

(781 kb)

23 Oct 2013 | External Publications

Taxation of foreign exchange gains and losses for corporates

Abdol Mostafavi and Craig Marston wrote "Taxation of foreign exchange gains and losses for corporates" for The Tax Institute's Corporate Tax Masterclass. The paper was presented on 23 October 2013.

(753 kb)

16 May 2013 | External Publications

An Update on the Consolidation Regime (Part 2): Case Study

Craig Marston and Julian Pinson wrote and presented "An Update on the Consolidation Regime (Part 2): Case Study" at The Tax Institute's NSW 6th Annual Tax Forum held in Sydney on 16 May 2013.

(211 kb)