Registered AITI Tax Qualification Info and Questions

Hi, I was wondering if anyone who has sat the Part 2 exams could give me an idea of what study leave they took? I just signed up for the course but haven't discussed study leave with my manager yet. I work in a small firm so no one from here has done these exams for a while.

Thanks in advance.

Tax notes for sunday 9 Dec hopefully attached.

Hi Ya,

I'm not doing any calculations but I'm wondering also should I be doing some.

I'm on the same track as you with the share for share undertaking swap.

what way are you concluding? I was suggesting that the shares are issued to benedict directly because of the clawback if he sells the shares after6 years. but now i'm thinking I should be going the other way as the company has a higher base cost anyway even with the claw back and the divs being paid to the company would be better?

am I totally off track?

Hi, i am doing the assignment also. Totally confused now. Does s615 not apply only to company relief for the assets transferred, not the shares acquired. therefore is there not claw back in both instances for the sale of shares?

I too get a higher base for the two party swap, however retirement relief could apply where s587/s615 has been applied once the other conditions are satisified and limit cgt??

For Section 626B I thought that exemption does not apply to disposals of shares deriving the greater part of their value from Irish based land?

I was a bit confused with S615 as well, as far as I can see you need it to transfer the chargeable assets as a no gain no loss, so I talked about the courses be transferred. I am probably wrong.

Did not contact the mentor: She said do not contact her for technical stuff. Sure what else would I want her for.

Hey

I am thinking about doing foreign effective rate tax calculations for the dividend received. Am I way off with this or is this the correct route to be going down. So confused:(

I am going to deal with 5 years because that's what was asked, but if s.626B applies the clawback will have no effect,

I think S21B applies,

Re close company surcharge, look at part b the definition of investment income in S434 and that might get you out of the surcharge.

I have used very little case law, am I missing something? Have others used much?

I worked out the the double taxation relief, not sure whether its relevant or not

Has anyone decided what to do about the dividends paid to PHL? I was looking at s21B, but think this does not apply as its a payment of dividends from a sub to a parent and this is the reverse, isnt it? Then i thought maybe the Eu parent sub directive, but again, even though PHL will own 12% > 5%, doesnt FFL own 100% of PHL and therefore is the parent - any ideas, starting to go mad here:mad:

the DTA with portugal has this in the explanantory notes re a parent company:

No provision has been made in the Convention on the Portuguese side to allow, when calculating the Portuguese tax due on dividends paid by an Irish company to a Portuguese parent company, credit for the underlying corporation tax paid by the Irish company. Portuguese domestic rules will apply in such cases. On the Irish side, where dividends are paid by a Portuguese company to an Irish parent company (i.e. a company which holds directly or indirectly 25 per cent or more of the capital in the company paying the dividend), credit will be granted when those dividends are being taxed in Ireland for the underlying Portuguese company tax on those dividends.


does the directive still apply then?

Hi WildRosie did you include the day of the exam in the four days per subject or was that just the run up to the exam week? Trying to work out study leave here as well

has anyone explored the option of the share for underataking 2 party swap , relief under s631 , keep the shares for 6 years , no CGT clawback
Any uplift shares exempt from CGT under 626B and then dividends are not taken into account for close co surcharge so in effect can stay in company , then liquidate PHL and take out all funds after 6 years ?

I'm getting interested in doing the AITI exams but I'm worried about the lack of flexibility in that you can only work in the Irish system. Am I wrong to think that?

Just wondering does anyone know whether you have to present to sit all four exams? I'm scheduled to sit my part 3 exams in may but am now unsure if I will get the time off work. Have passed my interim exams and would not like to have to do them again.

elinRB wrote: »

I know quite a few people with the AITI who work outside of Ireland with it.

Have a look at the website http://taxinstitute.ie/CareersandCourses/AITICharteredTaxAdviserCTAQualification/AITICharteredTaxAdviserCTAQualification.aspx and http://taxinstitute.ie/CareersandCourses/AITICharteredTaxAdviserCTAQualification/Anexcitingcareerintax.aspx for examples the ITI have of people working abroad

Once you can read and interpret legislation, that's transferrable across jurisdictions. That so many jurisdictions have legal and tax systems that are based on the UK one is also helpful when looking abroad.

+1 on the above

I'm AITI qualified and in a tax job in Australia. The qualification was not instantly recognisable to some employers when I was job hunting but the fact that I could explain my ability to interpret legislation, it certainly proved beneficial. It is quite easy to demonstrate that you have the skills to quickly learn the core principals of a foreign tax system as you have done it before in your own country in great detail through the AITI program.

I think Australia is a good example of where the qualification can be very useful as the legal system is largely based on the UK (as is our own)

Hi folks, does anyone when the ITI will release dates in relation to the winter course 2013?

Thanks in advance.