What the new CFC amendments mean for Australians structuring their investments into the United States of America through LLCs
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Structuring an overseas business investment raises questions on whether branches or separate entities should be established. Recent amendments to Australians investing into the United States via LLCs provide an opportunity for Australians to circumvent the United States' classical tax system and Australia's own CFC rules. After providing an overview of LLCs, this article will consider how the recent Australian tax amendments affect investments via LLCs. While welcomed, various problems are highlighted which may present problems for Australians utilizing LLCs.
Asia Pacific Tax Bulletin
Copyright 2008 International Bureau of Fiscal Documentation. The attached file is posted here with permission of the copyright owner for your personal use only. No further distribution permitted. Please refer to the journal's website for access to the definitive, published version.