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M&A – Navigating tax in the Risks & Opportunities that exist in a post-COVID world presentation
Published on 10 Aug 22 by NATIONAL DIVISION, THE TAX INSTITUTE
This presentation covers:
- CGT rollovers: including in subdiv 615 and 125 and the “and nothing else” requirement, J1 event if you have applied 126-B rollover previously, impact on cost bases, impact on ESIC requirements
- Debt forgiveness rules: In particular debt for equity swaps and the potential impact on tax attributes of the group
- Asset versus share acquisition: Quirks of the tax consolidation regime that can have an impact on value of your acquisition, including application of Instant Asset Write Off, Temporary Full Expensing and Small Business Depreciation to the ACA process, entry history rule, understanding how the “step-up” works.
- Contractual terms: Conditions precedent and conditions subsequent and the impact on timing of CGT event, and covering off on relevant indemnities.
- Financing arrangements: Understanding critical aspects of Div 974 for the purposes of funding your acquisition, but also the aspects that may impact a target, including the Hybrid Mismatch rules in Div 832.
Author profile
Mark D'Angelica FTI
Mark has over 13 years’ experience in providing advice on all areas of State and Federal tax, including corporate tax, international tax, tax effect accounting, PRRT, GST, employment taxes, transfer pricing, R&D tax incentive, payroll tax, state royalties and stamp duty. He was the Tax Manager of Beach Energy for 8 years and was key figure in the implementation of new financial reporting systems, mergers and acquisitions, providing strategic tax ad-vice, implementing tax governance framework and liaising with the ATO and AusIndustry. - Current at 11 May 2022
This was presented at Barossa Convention .
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