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TSA: legal and tax perspectives
Published on 26 Dec 02 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This seminar paper discusses what happens if the head company in the consolidated group fails to pay its tax liabilities, how the group can arrange for intra-group payments so that the head company has funds to pay its tax liabilities, and what happens in an M&A transaction in respect of an entity in a consolidated group that is sold to a third party purchaser.
Author profile
Michael Bersten
Michael is a Partner with PricewaterhouseCoopers Legal and is the leader of the PricwaterhouseCoopers Legal Tax Controversy Practice. Michael was formerly an ATO Deputy Chief Tax Counsel and Deputy Australian Government Solicitor. - Current at 26 July 2006
This was presented at Consolidation: Accounting & Tax Sharing Agreements .
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TSA: legal and tax perspectives
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Case studies on TSAs/reasonable allocation
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Accounting for tax consolidation
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