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Consolidations - some tips and traps paper

Published on 24 May 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper is a non-exhaustive journey through some of the traps embedded in the Consolidations regime and suggestions about dealing with them, including:

  • using a consolidated group as a bid vehicle
  • bad and doubtful debts of a joining entity - a legislative botch-up
  • deferred tax liabilities - complex on joining and double tax on exit
  • over-depreciation adjustment - it can apply again and again and again
  • the unrealised loss rules - three choices, but they’re a Hobson’s choice
  • at what time of the day does a group acquire a new member?
  • accrued liabilities on entry that are recognised later for tax.

Author profile:

Geoffrey Lehmann
Geoff is a Tax Counsel with PricewaterhouseCoopers. He has been involved in the development of the consolidation provisions as a member of Treasury's Consolidation Joint Design Team. He is a Taxation Institute representative on the Consolidation Subcommittee of the National Tax Liaison Group. Current at 11 April 2007 Click here to expand/collapse more articles by Geoff LEHMANN.
 

This was presented at Manoeuvring the Maze: Tax Forum.

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