User:Mike Leon

Code 203 – "How to Determine Source of Profit and Implement Effective Offshore Planning".

Objectives
To enable participants to understand how to determine the source of profit and apply the rules to their daily work in implementing effective offshore planning.

Contents

 * Explanation and application of the source principles to various types of businesses as provided in DIPN 21
 * Operations test
 * Contract effected test
 * Provision of credit test
 * Registration test
 * Totality of facts
 * How the above tests and rules applied to different types of transactions such as manufacturing, trading, provision of services, money-lending, use of intellectual property, provision of guarantee and e-commerce etc.
 * Cases for discussion including Whampoa Dock, Hang Seng Bank, TVB International, Euro Tech, Wardley Investment, Magna, Orion Caribbean, Emerson Radio, Kwong Mile, Consco Trading, Indosuez WI Carr, ING, Baring Securities, Kim Eng Securities, and advance ruling cases

Lecturer
Mr. Ho, LL.B, LL.M., MBA, MCS, FCPA, FCCA, FTIHK, Barrister-at-law, Principal Lecturer, FTMS.