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SME demergers and capital returns – Is the small business restructure roll-over the answer? presentation

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Published on 31 May 18 by QUEENSLAND DIVISION, THE TAX INSTITUTE

This presentation covers:

  • demerger
  • what is a demerger?
  • CGT - the Div 125 conditions
  • rollover - owners in head entity
  • dividend relief
  • consequences of 45B applying?
  • active assets.

Author profiles

John Middleton CTA
John Middleton, CTA, is part of the ATO’s Tax Counsel Network, where he works on complex technical advice, tax reform projects, and strategic litigation. He also worked in Policy and Law Design within the ATO. Prior to this, he had over 20 years in the private sector at Clayton Utz Brisbane specialising in revenue and commercial law. He practised in CGT, stamp duty, GST and general tax, as well as trust and corporate law. While in private practice John was listed in Doyle’s and Best Lawyers in respect of revenue law matters. - Current at 11 September 2025
Click here to expand/collapse more articles by John MIDDLETON.
Christine PALMER
Click here to expand/collapse more articles by Christine PALMER.

 

This was presented at 2018 Private Business Tax Retreat .

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