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Annual Corporate Tax Intensive

Published on 26 Oct 2006 | Took place at Hunter Valley Gardens, NSW

The program for this event featured experts in their respective fields examining a number of current corporate tax issues.

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Individual sessions

Managing communications and tax risk in a corporate tax group - an internal view

Author(s):  Chris MILLETT

“Say nothing” is a mantra that does not work in a corporate situation including:

  • communicating with the board of directors/audit committee
  • impact of disclosing board papers/directors minutes to the ATO
  • communicating with the other parts of the management, internal auditors and external auditors
  • communicating with external advisers
  • communicating with the ATO
  • keeping track of all the communications
  • requests for a BPR
  • impact of the promoter penalties
  • appropriate governance protocols
  • how do you find out what you don’t know but (based on hindsight) you do need to know?
Materials from this session:

Making the most of limited resources in tax due diligence

Author(s):  Grant WARDELL-JOHNSON

Normally due diligence is carried out where a consolidated group is acquiring another consolidated group or a stand alone entity or group of entities - are you looking at the most significant matters or are the entities being acquired bringing unrecognised problems into the group? This paper covers topics including:

  • joint and several liability exposure arising from membership of previous consolidated groups - lack of visibility
  • risks from open assessment periods beyond four years
  • latent tax liabilities which could be triggered on acquisition, for example
    • CGT events L3, L5 and J1
    • crystalisation of unrealised gains
  • limitations on availability and utilisation of tax attributes
    • changes in relative market values of group companies
    • impact of gearing on available fraction calculations
    • capital injection and other adjustments
  • structural tax issues for the carry-forward entity arising from historical positions.
Materials from this session:

Share capital tainting

Author(s):  Richard BUCHANAN

What flows from the Tax Laws Amendment (2006 Measures No 3) Bill 2006, introduced into the House of Representatives on 25 May 2006? This paper covers topics including:

  • what is share capital account tainting and where has it been?
  • what consequences does tainting share capital have for companies and their shareholders?
  • share capital account tainting and AIFRS - do we have a resolution for this risk?
  • how does share capital account tainting interact with tax consolidation?
  • what do these provisions mean for share based payment transactions?
Materials from this session:

ROSA: not just a pretty name - managing compliance post ROSA

Author(s):  Andrew MILLS

This paper examines the effect of the recent legislative changes to assessments, amendments, rulings and penalties and how they impact on the way tax advisers and tax managers should be managing compliance obligations including:

  • overview of the new rules for assessments, amendments and rulings including Part IVA amendment periods
  • are you really now protected if you have a loss or no assessment?
  • how do you ensure that you’re covered? When and what you have as a private ruling - tips and traps
  • is there any value in oral rulings?
  • what constitutes a public ruling and how much can you now rely on them?
  • the new penalty regime - GIC, SIC and the ATO’s new practice statement.
Materials from this session:

Managing dealings within a corporate tax group and with the ATO - an external view

Author(s):  Craig JACKSON,  Fiona MOORE,  Timothy DALTON

This paper looks at these matters from an external perspective including:

  • does the company/board have a tax risk charter and what are its advantages?
  • what processes have you established to deal with assessing tax risk on transactions?
  • how do you brief management/board on tax risk without creating or elevating the risk in doing this?
  • the ATO Board papers privilege and the limitations of this
  • recent developments in LPP (including the Rio decision)
  • how do you determine the appropriate strategy for dealing with the ATO
  • controlling the interaction of the ATO with the organisation so that there are "no surprises"
  • managing information flows and responses during an ATO investigation stage.
Materials from this session: