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Published on 09 Sep 04
by VICTORIAN DIVISION, THE TAX INSTITUTE
The rules for use of tax losses have once again been subjected to considerable change. This paper analyses the recent reforms as they affect corporate groups. Case studies are used to analyse:
- the new continuity of ownership test
- impact of the abolition of the same business test on corporate acquisitions
- the same business test applied to consolidated groups
- tricks in applying pre consolidation losses to post consolidation gains
- the loss denial rules.
Brad, a Senior Associate with Allens Arthur Robinson, practices in international and corporate taxation. He has experience in a wide range of income tax matters including sales, acquisitions and restructures, financing arrangements, and advising companies on the impact of tax consolidation in M&A transactions. Current at 23 July 2004
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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