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Division 250 presentation

Member Price: Free
Non Member Price: $15.00

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Published on 27 Aug 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

Division 250 had a difficult birth and is proving to be a troublesome infant. The law is derived from anti-avoidance issues connected with dealing with tax exempt state government entities but it now has an impact on ordinary, commercial real estate transactions. This presentation considers some of the practical difficulties and unresolved issues arising from the application of Division 250, including:

  • the impact of financing multiple properties with single debt facility
  • what is the most appropriate measure of expected financial benefits?
  • how to calculate the value of a building at the end of an arrangement
  • whether it is appropriate to apply Division 250 to foreign property held through a foreign entity
  • the impact of borrowing from an offshore financial institution on the limited recourse debt test.

Author profiles

Brian Lawrence
Brian Lawrence FTIA is a Partner with PricewaterhouseCoopers. He has specialised in corporate tax for over 20 years and has been involved in many corporate activities including mergers, acquisitions and Initial Public Offerings. Main client responsibilities include property companies, property trusts, property developers, banks, financial institutions and funds management activities. Clients include major Australian corporate groups. Brian has extensive experience advising on real estate tax matters including IPOs for a significant number of listed property trusts and property syndicates, sale and leasebacks and the establishment of numerous funds and stapled structures. He also has extensive experience in performing tax due diligence work on acquisitions. - Current at 27 August 2008
Click here to expand/collapse more articles by Brian LAWRENCE.
Michael COX
Click here to expand/collapse more articles by Michael COX.

 

This was presented at 6th Annual Property Intensive .

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Individual sessions

Recent changes to the taxation of real estate investment vehicles in Australia

Author(s):  John AVERY,  Simon Clark

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Division 250

Author(s):  Brian LAWRENCE,  Michael COX

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International tax developments

Author(s):  Peter B STINSON

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Further details about this event:

 

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