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.
Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. Current at 12 February 2016
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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
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