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Source - the last frontier in the Commissioner's mission to tax private equity profits.

Publication date: 28 Nov 11 | Source: CCH TAX WEEK

Issue: Issue 44, 17 Nov 2011

Pages: pp. 1-3


On 26 October 2011, the Commissioner released TD 2011/24 which considers the issue of source in the context of leveraged buy-out (LBO) arrangements — specifically the LBO involving Texas Pacific Group (TPG). TD 2011/24 was previously issued as TD 2010/D7. The Commissioner’s view in TD 2011/24 is that in respect of profits derived from the sale of shares in an Australian corporate group acquired in an LBO, the source of income is not dependent solely on where the purchase and sale contracts are executed.

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Author profiles

Tim Loh CTA
Tim is a Lawyer at Blake Dawson. - Current at 01 February 2011
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Marcus Ryan CTA
Marcus is a senior associate in the Tax Group of Ashurst, focusing on the Australian tax aspects of a wide range of corporate and financial arrangements. Marcus is a Chartered Tax Adviser, has worked in both the Perth and Sydney offices of Ashurst and has twelve years of experience in providing advice on both direct and indirect taxes to both Australian and foreign clients, across a number of industries sectors and government enterprises. - Current at 11 March 2013
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Paul O'Donnell CTA
Paul is a partner at Blake Dawson Waldron. He is an experienced tax practitioner with particular expertise in income tax consulting mainly in the area of structured, asset and project financing. He also has significant experience in advising on the corporate tax affairs of Australian and foreign owned banking groups. - Current at 20 June 2007
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