This paper 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.