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  Miscellaneous 2006

Mergers and acquistions in a post-consolidation world

Source: National

Published Date: 16 Feb 2006

 

This presentation examines the following topical issues affecting M & A transactions involving tax consolidated groups:

  • the effect of an SBT ceiling on the ability of a bidder to acquire the carry-forward losses of a target entity
  • the effect of an SBT ceiling on the ability of a bidder to claim bad debt deductions for debts "inherited" from a target entity
  • the characterisation of the sale of membership interests in subsidiary members, particulary in having regard to the quantum of capital losses currently existing in the tax system
  • whether a consolidated group will be denied a loss on the sale of a loss-making subsidiary member , if the subsidiary member is sold to another consolidated group

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Author(s)

Individual Session

Mergers and acquisitions in a post-consolidation world

Author(s): Martin Fry FTI
Materials from this session:

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Details

  • Published By: Martin Fry FTI
  • Published On:16 Feb 2006
  • Took place at:Hyatt Regency, Sanctuary Cove

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