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1st National Consolidation Symposium
Published on 03 Feb 2003 | Took place at Peppers Fairmont Resort, Leura, National
The recently enacted consolidation regime is the most significant corporate tax developmet in at least the last 17 years. Therefore, the Taxation Institute and the Corporate Tax Association determined that the critical importance of the issues raised dictated the convening of this joint 1st National Consolidation Symposium.
Get a 20% discount when you buy all the items from this event.
Individual sessions
General consolidation regime key new tax concepts
Author(s):
AH (Tony) SLATER
This seminar paper discusses the implications of the principles of 'single entity' and 'inherited history'.
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ACA steps and revenue protection measures
Author(s):
James TARGETT
This seminar paper discusses a detailed review of tax aspects, accounting standards input re Australian GAAP, possible retrospective ACA adjustments when liability 'settled', profits/tax losses 'accuring', step 3 franking and transition, tax losses, plants & intangibles.
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Partnerships and trusts
Author(s):
Richard HENDRIKS
This seminar paper discusses membership rules for trusts and partnerships, specific issues for asset tax value setting, treatment of tax losses and leaving a group.
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Exiting a group
Author(s):
Ray L CONWELL
This seminar discusses exiting a group, including: rebuilding debt and equity cost base, identifying the exiting assets, other intra-group assets, exit history rule implications, joint and several liability.
An edited version of this paper was published in two parts in the May and June 2003 editions of Taxation in Australia.
- Click here to view the first part
- Click here to view the second part.
Materials from this session:
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Finance assets ACA
Author(s):
Chris KINSELLA,
Cathy MCBRIDE
This seminar paper looks at the calculation of ACA including foreign exchange gains and liabilites, the boundary line between retained cost base assets and reset cost base assets, allocation of ACA - derivatives, and treatment of leased assets.
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MECs
Author(s):
Michael CHARLES
This convention paper discusses the members of a multiple entry consolidated (MEC) group, when a MEC group forms, the asset cost setting rules, losses, value shifting & loss integrity modifications for MEC.
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Capital allowance ACA
Author(s):
Peter MURRAY,
Sid HAMMELL
This convention paper discusses capital allowances, with a focus on: establishing the cost setting amount, over depreciated asset adjustment, successive application of over depreciated asset adjustment on subsequent acquisition, impact on depreciation rates and effective life, treatment of mining rights rights and ex-GBE assets, market valuation requirements, and cost base of exiting entities.
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Tax losses - available fractions
Author(s):
Glenn DAVIES
This seminar paper discusses loss integrity value shifting interface, with a focus: on entry/formation, during consolidation, and on leaving.
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Practicalities for small corporate groups
Author(s):
Annamaria CAREY
This convention paper discusses practicalities for small corporate groups, including: consolidation and SMEs, can your group consolidate, the benefits of consolidation for an SME group, the consolidation process, issues to be aware of in making the decision to consolidate, changes to the group post consolidation.
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Tax sharing arrangements
Author(s):
Matt HAYES,
Murray ALDRIDGE
This convention paper discusses tax sharing arrangements, including issues in drafting, practicalities in applying TSAs, director's duties, and whether a TSA actually stands up to the blow-torch of litigation in a corporate collapse?
An updated version of this paper was presented at the Tax Sharing Agreements - Tax & Legal Issues seminar on 30 July 2003. Click here to view that paper.
Materials from this session:
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Tax losses - available fractions
Author(s):
Paul ABBEY,
Joe CAMENZULI
This convention paper focuses on tax losses, including: establishing the available fraction, what is an injection of capital, curiosities in value and loss donation.
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Specific ATO aspects
Author(s):
Jim KILLALY
This convention paper discusses specific ATO aspects of consolidation, including: taxpayer assistance, rulings - public & private, tax audit strategies, compliance and systems issues, recognition of the practical difficulties associated with many of the calculations issues - consequences of getting it wrong.
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Mergers and acquisitions - due diligence
Author(s):
Tony STOLAREK
This convention paper discusses due diligence in relation to mergers and acquisitions.
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Treasury aspects: corporate taxation - where to from here?
Author(s):
Paul MCCULLOUGH
This convention paper discusses treasury aspects of corporate taxation, including: macro and micro policy issues, drafting legislation, resolving issues/problems - the ATO or Treasury, and interacting with taxpayers.
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Contractual aspects (consolidations)
Author(s):
Grant CATHRO
This powerpoint presentation discusses the contractual aspects of consolidations, including: drafting a Share Sale Agreement - issues raised by consolidation, avoiding responsibility for the taxes of the vendor group, beneficial ownership - precisely when does it change, leaving 'clean'.
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Eligibility and SBT
Author(s):
Trevor R HUGHES
This powerpoint presentation discusses eligibility and SBT, including: transferring losses into consolidated groups, 'entry' eligibility rules, transition rules - COT losses, utilisation - amount & order of recoupment, applicability of SBT in a consolidated group.
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Overview of Commercial & Technical Implications
Author(s):
Ken SPENCE
This presentation covers the following topics:
An updated version of the accompanying seminar paper was presented by Ken Spence at the Consolidations: Shattering the Myth of Complexity seminar in Sydney on 11 June 2003. Click here to view this paper.
- from a 'big picture' perspective, the areas currently causing the most difficulty and the likely long term pitfalls
- the impact that consolidation will have on commercial transactions
- lessons to be learned to date from the evolution of the consolidation legislation.Materials from this session:
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