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Will my deductions be disallowed under Division 16D or s51AD or the new rules replacing them? paper


The government has been grappling with a new regime to regulate the allowance of deductions where government bodies, other tax exempts and non-residents lease assets from private owners, are involved in certain financing transactions or where there is the private provision of public infrastructure. This session looks at where they are up to, including:

  • How we got to the current position
  • Some of the difficulties in applying the current legislation
  • The new rules - how they should work
  • Effective dates and the transition from s51AD & Div 16D to the new rules 

Author profile

Michael WILEY
Michael is presently engaged as a Consultant with Macquarie Bank. Prior to that Michael was also a Consultant with Goldman Sachs and for 15 years a Tax Partner with the law firm Mallesons Stephen Jaques. During his time at Mallesons, Michael served variously in the capacity as both head of the tax expert group in Sydney and as Partner in Charge of the Sydney office. During nearly all of his professional life Michael has specialised in the taxation aspects of financing and corporate mergers and acquisitions. In this capacity Michael has been advising on the privatisation of Government assets and the private provision of infrastructure since the very earliest days of such arrangements.
Current at 14 November 2005


This was presented at 21st National Convention: Beyond the Sea .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Section 8-1: Making certain that you receive what you are entitled to

Author(s):  Allan W BLAIKIE

Materials from this session:

Non-resident beneficiaries - income tax

Author(s):  Terry MURPHY

Materials from this session:

The major continuing compliance issues for ATO on Consolidations

Author(s):  Peter COAKLEY

Materials from this session:

The current imputation system - Traps and opportunities

Author(s):  Jane MADDEN

Materials from this session:

CGT - old chestnuts and emerging issues

Author(s):  Gordon S COOPER

Materials from this session:

Further details about this event:


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