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4th National Consolidation Symposium

Published on 01 May 2009 | Took place at Sheraton on the Park, Sydney, National

This event was also held on 29 April 2009 at the Hilton at Melbourne International Airport. Any differences in sessions delivered are noted (e.g. a paper delivered at only one of the venues).

The objective of this event was to provide both experienced and inexperienced practitioners with an opportunity to further develop their skills in tax consolidation.

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Individual sessions

Consolidations and accounting – Traps and opportunities

Author(s):  Ronen VEXLER,  David ROMANS,  Belinda HARRISON

This paper covers:

  • surprising outcomes in a volatile market
  • significance of accounting decisions
  • accounting issues flowing from consolidations
  • managing accounting outcomes
  • deferred tax - things to know now and IAS 12 changes.
Materials from this session:

ATO perspective on consolidation - Unravelling the mysteries of the single entity rule

Author(s):  Des MALONEY,  Peter WALMSLEY

This paper covers:

  • some history
  • what is the SER?
  • the divisional model
  • the commissioner's formal view of the meaning and application of the SER
  • matters that are currently being examined by the ATO
  • a compendium of ATO views that address SER issues.
Materials from this session:

TOFA and tax consolidation

Author(s):  Julian HUMPHREY,  Mark POOLE

This presentation covers the interaction of TOFA with the tax consolidation regime, including:

  • joining and leaving a tax consolidated group
  • elections and balancing adjustments
  • tax cost setting rules for Division 230 financial assets and financial liabilities
  • the ATO perspective
  • outstanding issues.
Materials from this session:

M&A and consolidation: New restructure rules

Author(s):  Richard HENDRIKS

This paper covers:

  • background - what was at stake and what was the concern?
  • what the recent amendments seek to achieve
  • the start date for the amendments
  • the threshold test - "restructure"
  • the impact of the amendments on cost base
  • the replacement entity's choice to deny roll-over relief
  • the "stick" option for the target's assets
  • a worked example of the cost base outcomes in a tax consolidation context
  • scrip-for-scrip acquisitions - the new tax landscape
  • a restructure which meets the requirements of Subdivision 124-G
  • a restructure using CGT rollover under Subdivision 124-M involving a non-widely held target and acquiring company
  • a restructure using CGT rollover under Subdivision 124-M involving a widely held target or acquiring company
  • non-restructure using CGT rollover under Subdivision 124-M.
Materials from this session:

Consolidation: Bringing it all together in 2009

Author(s):  Richard CZERWIK,  Brian LANE

This paper provides corporate tax directors and management with a high level and practical overview of developments and issues impacting key areas of tax consolidation, including the effect of:

  • the single entity rule
  • tax cost setting rules
  • losses
  • tax sharing agreements issues, in the context of merger and acquisition transactions.
Materials from this session:

Consolidation: Legislative changes (Part A) – ACA related amendments

Author(s):  Ken SPENCE

This paper provides a detailed examination of the critically important pending legislative amendments involving:

  • entry allocable cost amount calculations
  • the impacts of resetting the value of an asset and interactions with the entry history rule
  • the practical implications of retrospectivity.
Materials from this session:

Where are the cost setting rules in 2009?

Author(s):  Michael CHARLES,  Geoffrey YIU

The asset cost setting rules are the core of consolidation but there are surprises in their application. This paper reviews the fundamentals of the process with a focus on refreshing understanding and addressing issues that arise in practice including:

  • asset identification and allocation
  • goodwill and the accounting interface
  • what is a retained cost base asset?
  • revisiting previous settings
  • setting values on exit
  • emerging issues.
Materials from this session:

Consolidation: Legislative changes (Part B)

Author(s):  Peter MURRAY

This paper provides a detailed examination of the critically important pending legislative amendments involving:

  • post-joining time liabilities adjustments
  • exit allocable cost amount calculations
  • MEC groups
  • CGT straddle transactions
  • extension of the single entity rule
  • the practical implications of retrospectivity.
Materials from this session:

Consolidation and mining assets – Some selected acquisition issues checklist

Author(s):  Cameron RIDER

This paper covers:

  • tax cost setting and pre- and post-ACA mining leases
  • tax cost setting and exploration
  • single entity rule and exploration
  • impact of consolidation amendments
  • entry history rule and exploration
  • TOFA and commodity hedges.
Materials from this session:

Less than the sum of the parts: Tax losses of consolidated groups

Author(s):  Duncan R C BAXTER

This paper focuses on the problems that continue to affect tax losses of consolidated groups including:

  • quirks in the loss transfer tests
  • unrealised losses, RUNLs and LDPs - what's that all about?
  • the "same business test" and the entry/exit history rules
  • identifying the business of a consolidated group
  • calculating and re-calculating "available fractions"
  • the extra tests for re-transferred losses.
Materials from this session:

Tax consolidation – Financial services

Author(s):  Tony STOLAREK

This presentation considers particular financial services issues in dealing with the legislated and unlegislated consolidation measures, including:

  • what is a retained and reset cost base asset, including the treatment of marketable securities?
  • what is a liability that is recorded in the accounts, including the treatment of derivatives?
  • how do you identify all the particular assets and liabilities in financial services groups?
  • derivative transactions and consolidation, including the transition to TOFA stages 3 & 4
  • assets with volatile valuations, and the delay between acquiring control and joining time
  • tax sharing agreement issues with regulated entities
  • the many consolidation challenges of hybrid instruments.
Materials from this session:

Consolidation: Leaving – The sting in the tail

Author(s):  Hayden BENTLEY

This paper covers:

  • key issues in the exit ACA
  • when selling shares is not the same as selling assets
  • impact of legislative changes on the exit calculation.
Materials from this session:

Consolidation in the Courts

Author(s):  Michael FLYNN

This paper covers:

  • alternative judicial approaches to interpreting legislation
  • recent cases on interpretation of tax legislation, including Hastie Holdings
  • how a court is likely to approach Part IVA in the context of tax consolidation.
Materials from this session: