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Debt/equity: comments on recent developments, overseas experiences and Section 974-80 presentation

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Non Member Price: $15.00

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Published on 17 Nov 05 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • the distinction between debt and equity
  • comments on the US, UK and Canadian experience
  • current issues:
    • effect of solvency clauses for project finance, lower tier 2 capital
    • what if you cannot institute winding-up proceedings on a default by a company?
    • the effect of conversion rights and options, including TD 2004/D76
  • the ambit of section 974-80.

Author profiles

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. Martin represented the taxpayer in Shell Energy v Commissioner of Taxation before the Federal Court, Full Federal Court and High Court. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. Martin has extensive experience in contentious matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 28 September 2022
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Brad SCHWARZ
Brad, a Senior Associate with Allens Arthur Robinson, practices in international and corporate taxation. He has experience in a wide range of income tax matters including sales, acquisitions and restructures, financing arrangements, and advising companies on the impact of tax consolidation in M&A transactions.
Current at 23 July 2004
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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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