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The holding period and related payment rules: 45 days to offset
Published on 01 Feb 07 by "THE TAX SPECIALIST" JOURNAL ARTICLE
The holding period and related payment rules, which are part of the dividend imputation system, were introduced nearly a decade ago to correct certain “abuses” of the imputation system. In particular, these two rules were aimed at preventing trading in franking credits, whereby those taxpayers who could most benefit from the imputation system were able to access its benefits in place of those who could not fully utilise its benefits. The broad application of the rules is by now generally understood by participants in the share market. However, in the opinion of the authors of this paper, there are still some issues associated with the application of the rules which deserve further consideration and comment.
In this paper, Patrick Broughan and Alison Noble discuss in detail a number of issues impacting the application of these rules which remain unresolved by taxpayers who participate in the share market.
Author profiles
Patrick Broughan
Patrick Broughan FTIA is a Partner in Deloitte’s Melbourne based Financial Services Tax Group. Patrick has 27 years experience in tax, both within the Big Four and within a financial services group. Patrick is known for the articles he has written for the Australian Securities Exchange for general investor education, and is a lecturer at the University of Melbourne. Patrick has substantial expertise in the taxation of financing transactions, including funds management, restructuring, de-mergers, acquisitions, divestments and complex capital raisings and reductions. - Current at 06 May 2009
Alison Noble ATI
Alison is a principal with Deloitte. - Current at 01 February 2009
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