In the last few years the tax residence of companies and individuals has been challenged by the ATO resulting in a large number of reported decisions. Those decisions are considered, as is the resident status of trusts, and the characterisation of civil law entities as either companies or trusts for [...]
PRÉCIS Increasingly, clients are holding assets in multiple jurisdictions. This may be driven by a number of factors, such as taxation (direct and inheritance), forced heirship or testators family maintenance legislation, asset protection concerns, including liability under family law and bankruptcy legislation. It is sometimes also driven by the need to spread wealth between countries, [...]
