The Issues Papers related to the reform of the foreign source income anti-deferral regimes, including controlled foreign corporation (CFC), Foreign Investment Fund, transferor trust and deemed present entitlement rules, were released for discussion by the Board of Taxation on 19 May 2008. The Issues Papers follow the position paper released in January 2008 and discussion paper released on 12 March 2008.
The previous papers provided high-level views on the general prin…