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  Miscellaneous 2007

'The con' - broken bits in the income tax consolidation rules

Source: Western Australia

Published Date: 11 Aug 2007

 

Various aspects of the income tax consolidation rules in Part 3-90 of the Income Tax Assessment Act 1997 (Cth) still do not work properly. This presentation focusses on a number of these aspects, including:

  • the operation of the company loss recoupment rules as loss transfer tests
  • the modifications to the 'same business test' for income tax consolidated groups
  • peculiar outcomes under the 'single entity rule'
  • the private ruling system and restructures of consolidated groups
  • weaknesses in the Tax Sharing Agreement and 'clear exit payment' rules
  • anomalies in relation to CGT event L5 and the acquisition of a consolidated group
  • the exclusion from CGT event J1 in relation to entities that leave:
    • income tax consolidated groups
    • multiple entry consolidated (MEC) groups
These aspects also provide a context within which the presentation considers a selection of recent legislative amendments and ATO rulings.

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Author(s)

Individual Session

'The con' - broken bits in the income tax consolidation rules

Author(s): Duncan R C Baxter
Materials from this session:

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Details

  • Published By: Duncan R C Baxter
  • Published On:11 Aug 2007
  • Took place at:Abbey Beach Resort, Busselton

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