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Capital raising and the debt/equity borderline paper

Published on 17 Feb 06 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

After a brief overview of the regulatory capital rules for ADIs, this paper then considers the key Australian income tax implications relevant to the issue of various types of instruments which qualify as some sort of regulatory capital.

Author profile

Anthony Frost CTA
Photo of author, Tony FROST Tony Frost in his first, 34-year career was one of Australia’s leading corporate tax advisers. He was, and still is, a lawyer and a Chartered Accountant. His clients included BHP Billiton, Macquarie Bank, Westpac Banking Corporation and the Commonwealth Bank of Australia. Before joining Greenwoods in 2003, he had been a tax partner at PwC for seven years. Prior to that, Tony spent five years working in-house at Westpac Banking Corporation. Throughout his tax career, Tony was a regular speaker at TTI events. Tony finished his tax career in 2018, after being Managing Partner, for seven years, of tax advisory firm Greenwoods & Herbert Smith Freehills, one of Australia’s most lauded professional service firms. Since 2019, and after completing a Master of Science in Coaching Psychology degree at the University of Sydney, Tony has been having a second career as an executive coach, mentor, leadership consultant, facilitator and trainer. He holds a number of non-executive company directorships and is the non-executive Chairman of the Leadenhall Valuation Services group. Tony is a graduate of the Australian Institute of Company Directors and now teaches the AICD’s prestigious Company Directors’ Course. Tony is also the author of The Professional: A Playbook to Unleash Your Potential and Futureproof Your Success, Tony has been a proud member of The Tax Institute for about 40 years. - Current at 06 July 2026
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This was presented at 2006 Financial Services Taxation Conference: From every angle .

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Interpreting and applying the tax regime in practice - a legal perspective

Author(s):  Jennifer DAVIES

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Interpreting and applying the tax regime in practice - an ATO perspective

Author(s):  Ashley KING,  George HITTI

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