Description
Unlock smarter structures for investment properties, family enterprises, and cross border ventures with practical insights on using look through companies to optimise tax outcomes.
This webinar explores the use of look-through companies for holding residential properties and other investments, carrying on family-owned businesses, and for investment and business activities offshore.
Case studies will be used to highlight the tax issues arising with the use of look-through companies for different purposes. Specific issues that will be addressed include:
- The eligibility criteria for becoming (and continuing to be) a look-through company (including the application of the look-through counted test in unusual situations),
- The application of the bright-line test to look-through companies that own residential property (along with the application of the main home exclusion),
- The application of the de minimis threshold to the disposal of interests in look-through companies that own residential property,
- Dealing with overdrawn shareholder current accounts, the provision of fringe benefits, and related issues, and
- Calculating the tax cost of converting an ordinary company to a look-through company.
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LEARNING OUTCOMES
You will:
- Know when a look-through company should be used for a family-held business, as an active investment vehicle, and for cross-border investment.
- Learn about the criteria for a company to become, and remain, a look-through company.
- Understand how the look-through company rules interact with the bright-line rules.
- Be able to determine when an income tax liability arises on the disposal of interests in a look-through company.
- Learn about the rules concerning working owners, shareholder salaries, and fringe benefits tax.
- Know how to deal with distributions and overdrawn current accounts.
- Be able to calculate income arising on conversion of an ordinary company to a look-through company.
- Understand what tax implications arise when a company ceases to be a look-through company.
SUITED TO
Junior, intermediate and senior accountants, and lawyers who advise clients on structuring issues.
PRESENTER
Harry Waddell, Partner, Tomlinson Law
Harry is a partner at Tomlinson Law. Prior to joining Tomlinson Law, Harry worked as a senior tax manager in an international accounting firm. Harry has an LL.B. and a M.Com. (1st class honours) from the University of Canterbury, and is currently studying for a PhD part-time at the University of Canterbury. Harry has a particular interest in the taxation of look-through companies and has published both a thesis and a peer-reviewed journal article on this topic.