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Corporate Tax Intensive - Tough Tax Topics

Published on 17 Nov 2005 | Took place at Ettalong Beach Resort, NSW

These materials will provide you with complete coverage of the difficult tax issues currently facing tax advisers.

Get a 20% discount when you buy all the items from this event.

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Individual sessions

Tax loss recoupment - the evolving landscape

Author(s):  Jeremy HIRSCHHORN

This paper covers the new rules - a critique for corporates:

  • issues with new COT/SBT reforms
  • impact on bad debt claims
  • Subdivision 165-CC for corporate groups
  • utilisation of losses within consolidated groups - management of available fractions and adjustments
  • the ATO perspective on SBT satisfaction.
Materials from this session:

International tax reform - status and some emerging issues

Author(s):  Alf CAPITO

This paper covers:

  • latest issues arising from RITA reforms
  • foreign source income
  • capital gains exemptions
  • off shore developments
  • what you hadn't considered as an outcome of RITA.
Materials from this session:

Tax effective planning for global business arrangements

Author(s):  Andrew FISHER

This paper covers:

  • managing intellectual property
  • strategies for manufacturing
  • alternative distribution models
  • regional entrepreneurs
  • shared service providers and outsourcing.
Materials from this session:

Convergence: the M&A environment

Author(s):  Stef MASON

This paper covers:

  • the mechanics of undertaking mergers or acquisitions under IFRS
  • consolidation
  • de-consolidation
  • thin capitalisation
  • transfer pricing
  • disposals
  • restructuring.
Materials from this session:

Foreign currency gains and losses - the issues and traps

Author(s):  Neil WARD

This paper covers:

  • pre division 775 transactions and ERA source
  • core issues/problems with the Forex rules
  • tax effective hedging
  • tax/accounting differences
  • forex regulations
  • source
  • functional currency
  • interaction with CFC/FIF regimes
  • outstanding issues.
Materials from this session:

Taxation impacts of capital management

Author(s):  Mark FERRIER,  Tim KYLE

This paper covers:

  • the ATO's position
  • application of section 45B
  • alternatives:
    • special dividend
    • capital return/reduction
    • on-market buy-back
    • off-market buy-back
    • demergers (including stapling)
    • when interest deductions will be allowed.
This paper was also presented at the Capital Management Strategies seminar held in Perth on 9 March 2006.
Materials from this session:

Debt/equity: comments on recent developments, overseas experiences and Section 974-80

Author(s):  Martin FRY,  Brad SCHWARZ

This paper covers:

  • the distinction between debt and equity
  • comments on the US, UK and Canadian experience
  • current issues:
    • effect of solvency clauses for project finance, lower tier 2 capital
    • what if you cannot institute winding-up proceedings on a default by a company?
    • the effect of conversion rights and options, including TD 2004/D76
  • the ambit of section 974-80.
Materials from this session: