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International Tax Series - Part 6: Takeover: Sale to a multinational

Wednesday, 11 November 2020 - 12:30 PM to
1:30 PM
Event Coordinator: kathyxu@taxinstitute.com.au
     

Registration Time:

Member Price: $75.00

Non Member Price: $95.00

CPD hours:1.00

Part 6: Takeover: Sale to a multinational

Mask ‘R’ Us has received an approach to sell the entire business to a multinational enterprise Mega Corp. Jane and Judy now seek advice on the key tax considerations on exit.

Sale of whole business vs foreign subsidiaries? Where is the value, IP etc.

Exit event – CGT discount if sold at AusCo level and consideration of flow through trust consequences.

If sell at US HoldCo level, potential for no Australian CGT (768-G), but unfranked earnings sitting in vendor AusCo.

Consider AusCo implications of retaining Australian business and IP vs selling Australian business.

Comparison of overall Australian individual tax outcomes under sale of AusCo or US HoldCo.

If ForeignCo acquires AusCo, how do conduit foreign income rules operate for repatriation of ongoing profits, plus Taxable Australian Property (and potential withholding tax considerations) on subsequent exit.