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Capital management of financial institutions and the related tax issues presentation #1

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Published on 13 Feb 13 by NATIONAL DIVISION, THE TAX INSTITUTE

These presentations cover:

Basel III changes:

  • overview and background – concept of regulatory capital; interaction with ratings capital; Basel III changes; how much additional capital banks globally will have to raise; and what banks around the world are doing
  • Basel III changes - focus on Basel III changes; capital adequacy under new APS 111; what the different categories of capital comprise of; key features to qualify as Additional Tier 1 Capital and Tier 2 Capital; deductions from capital; transitional arrangements

Topical tax issues facing banks and insurance companies about capital management:

  • Tier 1 capital issues in Australia – tax implications for the issuer and security holders including the implications for the issuer arising from Basel III non-viability clauses and the application of various anti-avoidance rules
  • Tier 1 capital issues undertaken by foreign branches of Australian banks – issues for the bank including the application of s 215-10
  • Tier 2 capital issues in Australia – tax implications for the issuer and security holders including application of the debt/equity rules.

Author profile

Tricia Ho-Hudson
Tricia is the Head of Capital & Regulatory Strategy at the Commonwealth Bank of Australia. Tricia’s team is responsible for management of the capital of the Commonwealth Bank and its subsidiaries (approximately $35 billion), as well as strategic implementation of financial regulatory reform generally. The team is also responsible for execution of all capital transactions. Tricia is a member of the Tax and Capital Management Working Group coordinated by the Australian Bankers Association. - Current at 13 February 2013

 

This was presented at 2013 Financial Services Tax Conference .

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Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

Materials from this session:

The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks

Author(s):  Ian FULLERTON

Materials from this session:

Transfer pricing and funds management

Author(s):  Damian PRESHAW

Materials from this session:

Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

Materials from this session:

The shifting Part IVA landscape

Author(s):  Larry MAGID,  James PETTIGREW

Materials from this session:

Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

Materials from this session:

GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

Materials from this session:

Losses

Author(s):  Julian HUMPHREY

Materials from this session:

Capital management of financial institutions and the related tax issues

Author(s):  Tricia HO-HUDSON

Materials from this session:

The Rubik's Cube of tax - An update on trusts

Author(s):  Andrew MILLS,  Matt HARTSHORN

Materials from this session:

New R&D regime in financial services

Author(s):  Jamie MUNDY

Materials from this session:

The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

Materials from this session:

TOFA - A new world of economic substance?

Author(s):  Phillip COLE

Materials from this session:

Income tax case update

Author(s):  Cameron RIDER

Materials from this session:

Asset financing/thin capitalisation/infrastructure update

Author(s):  Steve FORD,  Arash AZIMI

Materials from this session:

MRRT and Carbon Tax: Issues for financiers and funds

Author(s):  Teresa DYSON

Materials from this session:

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