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Consolidation: How Aware are you of the Issues?
Published on 15 Feb 2001 | Took place at Swiss Grand Hotel, Bondi Beach, Sydney, NSW
The new Consolidation Regime will change the income tax landscape for all corporate groups. There are important planning issues for the acquisition or disposal of a wholly-owned entity and of particular assets. Group reorganisations, franking account planning, asset transfers and transfer of losses are all affected. This seminar ensures that you are aware of technical and practical issues under this new regime.
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Individual sessions
A Background to the New Consolidation Regime
Author(s):
David J WILLIAMS
A paper discussing the background to the new consolidation regime, including: The fundamental problem; Asprey Committee recommendations; Campbell Committee recommendations; Section 80G; CGT rollover relief; Ralph Committee recommendations.
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Consolidation: Overview
Author(s):
Christopher CATT,
Jim MCMILLAN
This paper consists on an overview of consolidations. It dicusses a number of issues such as: How do you become/cease to be a group?; Can I just use book values?; The end of the present grouping provisions; The end of rollovers; The proposed arms length rule; What happens to intercompany transactions after consolidation?; What happens to goodwill on consolidation?; What transition options are there? Acquiring a new company and commencing to be consolidated, what happens?; Selling a subsidiary and degrouping; How is franking account to be managed under consolidation?
Materials from this session:
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Bringing Losses into a Consolidated Group on Joining
Author(s):
Mark FERRIER
This paper looks at the issue of bringing losses into a consolidated group on joining. It discusses: Calculating and unutilised losses of a joining entity; Applying the transfer tests COT and SBT losses to the joining entity; Categorisation of transferred losses - what makes up a bundle.
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How to Utilise Losses Within a Consolidated Group
Author(s):
Tony COOPER
This paper looks at utilising losses within a consolidated group and discusses: Loss tests to be satisfied by the Consolidated Group; Order of loss utilisationby the Head Entity; Using concessional transferred losses; Using standard transferred losses; Calculating the loss factor; When is a loss factor varied?
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The Impact of Consolidation on the Tax Values of Assets
Author(s):
David WATKINS
This paper looks at the treatment of assets on joining, forming or leaving a consolidated group.
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International Aspects of Consolidations
Author(s):
Alf CAPITO
This paper looks at the international aspects of consolidation, including: Foreign owned groups with multiple entry holding companies - special rules; Structuring foreign investment into Australia under the consolidation regime; and how thin capitalisation, CFC and other international tax rules interact with the consolidation regime.
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Consolidation: How Aware are you of the Issues?
Author(s):
Michael BARBOUR
This paper discusses issues involved in consolidation, including: A corporate perspective; What happens if you don't consolidate?; Why you should defer/not defer consolidating groups; Are trusts able to be included in consolidated groups?; Should a holding companies and subsidiaries pay out dividends pre-consolidation?; Should companies be liquidated before consolidation commences? What is the difference between acquiring assets or acquiring shares in a target, under the consolidation regime?
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