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Top-hatting for SME’s paper

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Published on 11 Mar 20 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • what is top-hatting?
  • how to do you undertake a top-hatting restructure tax efficiently?
  • Division 615 – vanilla interposition
  • Subdivision 122-A
  • scrip for scrip rollover – Subdivision 124-M
  • rollover accounting issues and anomalies (the dividend trap).

Author profile

Stephen Holmes CTA
Photo of author, Stephen HOLMES Stephen Holmes, CTA is a Partner with WMS Chartered Accountants based on the Gold Coast. He has been practicing as an accountant since 1987 and has had a focus on tax since 1994. He specialises in all SME tax matters with a particular interest in the CGT small business concessions, tax effective restructures and Division 7A. Since 2011, Stephen has been a senior tax and superannuation trainer with CAANZ and has been instrumental in establishing dedicated tax training communities on both the Gold Coast and in Lismore for Northern NSW practitioners. He is passionate about tax education and assistance for regional accountants. He is also a regular speaker for other professional bodies including the Tax Institute. Stephen holds separate Masters degrees in both Taxation and Economics as well as a Bachelor of Business. More recently, he was awarded a Juris Doctor degree with first class honours from Bond University. - Current at 30 January 2025
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