International investment and trading is something that all taxpayers are familiar with – however when it comes to the tax treatment thereof, it is quite the opposite, where most taxpayers are unsure about what SARS requires.
This course aims to discuss the tax rules for international dealings Controlled Foreign Companies and Headquarter Companies.
This session will cover the following:
• Determination of whether something is a Controlled Foreign Company (CFC) and a Headquarter company (HQC)
• What happens when a company ceases to be a CFC or HQC
• The tax treatment of income and net income of CFC’s and HQC’s, including anti-avoidance rules
• Brief coverage of loop structures and the tax rules applicable to them
• Brief coverage of the administrative rules for CFC’s and HQC’s
This session will cover the following:
• Determination of whether something is a Controlled Foreign Company (CFC) and a Headquarter company (HQC)
• What happens when a company ceases to be a CFC or HQC
• The tax treatment of income and net income of CFC’s and HQC’s, including anti-avoidance rules
• Brief coverage of loop structures and the tax rules applicable to them
• Brief coverage of the administrative rules for CFC’s and HQC’s
