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Don't Burn Your Losses - 2003 NSW Annual Intensive Retreat
Published on 27 Nov 2003 | Took place at Crowne Plaza, Terrigal, NSW
This year's Terrigal Intensive concentrated on LOSSES - both inside Consolidations and outside Consolidations.
This seminars focuses on topics such as:
- Stand Alone Companies
- Transfer of Losses
- Losses in Australian Tax history
- The ATO Position on Losses
- Losses when buying or selling a company or company group
Get a 20% discount when you buy all the items from this event.
Individual sessions
Use of or Transfer of Losses (Non-Consolidation)
Author(s):
Mark FERRIER
Topics covered in this seminar paper include
- Whare are your options if prior tax loss transfers are denied on audit?
- The Commissioner's power to amend
- Can Part IVA apply to a s80G/Div 170 loss transfer?
- Does a s80G/Div 170 loss transferhave to be for a specified amount?
- Does the Commissioner have the power to permit late transfers?
- Div 170 versus s80G
- Impact of Value Shifting provisions
- Transfer of capital losses
Materials from this session:
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Losses & Trusts - Private
Author(s):
Robert GORDON
Topics covered in this seminar paper include:
- Categorisation of Trusts
- Corporate Unit Trusts and Public Trading Trusts
- Bad Debt Deductions
- Change of Ownership
- Family Trust Election - states of play
- Income injection test
- Outcomes
Materials from this session:
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Position of Losses in Australian Tax History
Author(s):
Graeme S COOPER
Topics covered in this seminar paper include:
- How did we get here? A review of the waves of attacks on losses
- Where are we now? Which regimes will survive consolidation?
- Where are we here? What policies lie behind the various loss rules? How are these policies implemented?
- What lies ahead?
Materials from this session:
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Stand Alone Companies - Continuity of Ownership Test
Author(s):
Adam GIBBS
Topics covered in this powerpoint presentation include:
- Types of losses relevant for COT
- COT - RBT changes
- Saving Rule - what is the tax loss?
- Division 166 modifications
- Part year tax losses
- Proposals for changes to COT
Materials from this session:
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Stand Alone Companies - Same Business Test
Author(s):
Christopher CATT
Topics covered in this powerpoint presentation include:
- The Law
- Impact of TLAB No. 5
- The Rulings
- The Future
Materials from this session:
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Some Aspects of the ATO Position in Relation to Losses
Author(s):
Michael BERSTEN
Topics covered in this powerpoint presentation include:
- A review of the ATO IDs dealing with losses
- ATO IDs and reasonably arguable position
- Anticipated Rulings and determinations concerning losses
- ATO compliance program as it related to losses
- Where is it likely to head?
Materials from this session:
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Deducting Losses within a Consolidated Group - Div 707c
Author(s):
David IRELAND
Topics covered in this powerpoint presentation include:
- Application of the COT test in a consolidated group
- Application of the SBT test in a consolidated group
- Other restrictions on a head entity deducting losses within a consolidated group
- Impact of available fractions
- Other restrictions and modifications
Materials from this session:
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Addressing Losses when Buying or Selling a Company
Author(s):
Tony STOLAREK
Topics covered in this seminar paper include:
- Impact in M & A transactions
- Are you buying additional undisclosed liabilities?
- Is it beneficial to clean up a company group before sale?
- Impact of Consolidations Regime on the sale contract
- Is loss trafficking likely to be a phoenix?
- Likely impact of Part IVA
Materials from this session:
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