Allocable Cost Amount - Steps 2, 3 & 4 seminar paper

Published on 29 Oct 03 by VICTORIAN DIVISION, THE TAX INSTITUTE

The issues covered in this seminar paper include:
- what liabilities are
- dealing with linked liabilities, and off-balance sheet liabilities
- allowing for present or future tax deductions
- issues relating to intercompany debts
- allowing for unrealised gains and losses
- debt/equity issues
- finance and operating leases
- provision for taxes and deferred tax liabilities
- discharge of liabilities and CGT event L7
- transitional treatment of unfrankable undistributable profits
- profits accruing to a group in a creeping takeover
- intragroup dividends and their impact on step 3
- profits which recoup losses.

Author profile

Tony STOLAREK

Tony is a Partner in the Ernst & Young National Tax Group and has been involved with tax consolidation since its creation emerging from the Ralph RBT. Tony was a member of the Tax Consolidation Joint Design team of Treasury, ATO and professionals, and remains a member of the NTLG Consolidation Subcommittee and various working groups dealing with consolidation practice, emerging law and ATO compliance initiatives for consolidating groups. Tony is a member of the ICAA National Tax Technical Committee and chairs it’s Consolidation Working Group.
Current at 9 February 2009

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• Tax Losses & Consolidations Workshop - 27-October-1999
• The new era for financing assets - 09-September-1999
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