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As the loss recoupment landscape continues to evolve - where exactly are we? presentation
Published on 17 Nov 05 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation 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.
Author profile
Jeremy Hirschhorn CTA
Jeremy Hirschhorn was appointed to the Second Commissioner role from 16 April 2020. He has overall responsibility for the ATO’s Client Engagement Group, which fosters willing participation in Australia’s tax and super systems through well-designed client experiences. Jeremy has more than 20 years' experience in roles managing complex tax matters. As Deputy Commissioner of Public Groups & International from April 2015, Jeremy was responsible for ensuring that the largest Australian and multinational companies were meeting their corporate tax obligations and providing the Australian community with confidence that these large companies were being held to account. Jeremy also worked as Chief Tax Counsel, with responsibility for the provision of the ATO’s legal advice in relation to interpretation of the tax and super laws, when he joined the ATO in August 2014.Prior to joining the ATO, Jeremy was a senior partner in KPMG’s tax practice. Jeremy holds a Bachelor of Commerce and Bachelor of Laws from the University of NSW. He is a Chartered Tax Adviser and Chartered Accountant. - Current at 12 January 2023
This was presented at Corporate Tax Intensive - Tough Tax Topics .
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Debt/equity: comments on recent developments, overseas experiences and Section 974-80
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