期刊名称：Journal of the Australasian Tax Teachers Association
印刷版ISSN：1832-911X
电子版ISSN：1832-911X
出版年度：2009
卷号：4
期号：1
出版社：Australasian Tax Teachers Association
摘要：One of the potential reforms to be considered by the Henry Review1is a proposalby the Institute of Chartered Accountants Australia and Deloitte for theintroduction of a tax transparent company (the ICAA proposal).2The centralproposition of the ICAA proposal is that the introduction of a tax transparentcompany will be beneficial to closely held businesses in Australia. An issuefacing closely held businesses can be in terms of financing, and this article willconsider whether the introduction of a tax transparent company is likely to assistclosely held businesses with this. This analysis will consider the model outlined inthe ICAA proposal, as well as a number of foreign transparent company forms,particularly: United States' S Corporations and limited liability companies (LLC),the United Kingdom's limited liability partnership (LLP) and New Zealand's LossAttribution Qualifying Company (LAQC). Through this analysis, a number ofareas of concern will be raised about the interaction of a tax transparentcompany with financing, particularly in terms of eligibility requirements,assessment for unpaid allocations, comparison to corporate tax treatment andactive members. It will be argued that as currently structured the ICAA proposalis unlikely to substantially assist closely held businesses address their financingproblems and that apartial loss transparent company would be preferable modelin this regard
