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Tax issues in restructures, acquisitions and dealing with distressed debt presentation

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Published on 19 Feb 14 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • distressed debt – common transactions
  • characterisation issues
  • key income tax issues for the debtor:
    • commercial debt forgiveness rules
    • limited recourse debt rules
  • key income tax issues for the creditor:
    • loss on extinguishment of debt (bad debt, general deduction,capital loss)
  • withholding tax
  • TOFA
  • key transactions:
    • renegotiating debt repayments
    • assignment of debt
    • debt for equity swap.

Author profile

Ian Kellock CTA
Photo of author, Ian KELLOCK Ian is a Tax Partner at Ashurst and has extensive experience in Australian corporate and international tax, advising Australian and foreignowned banking and financial services groups. Ian’s practice primarily focuses on due diligence and structuring for mergers, acquisitions and divestments, financing transactions and group reorganisations. Ian has significant recent experience advising on all income tax aspects of financing and refinancing transactions and asset and debt reconstruction projects. - Current at 29 May 2019
Click here to expand/collapse more articles by Ian KELLOCK.

 

This was presented at 2014 Financial Services Taxation Conference .

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