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Capital structuring for corporate groups presentation


This presentation examines some of the lessons from recent capital restructuring (including demergers) for corporate groups. It seeks to identify some of the pitfalls that can arise for entities seeking to undertake a capital restructure and some of the criteria for a successful capital restructure. Specifically discussed are:

  • the role of Subdivision 204-D and s177EA in capital management initiatives
  • the application of s45B in non-demerger capital management initiatives
  • the application of s45B to demergers including the draft practice statement
  • related CGT consequences.

Author profile

Gordon Thring CTA
Gordon is a Partner in the Corporate Tax practice of Deloitte. He has over 20 years experience in mining and energy, financial services and property sectors. He was extensively involved in the consultation arrangements regarding the introduction of Division 125 and the amendments to s45B to accommodate demerger relief. - Current at 19 March 2009
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This was presented at 44th Victorian State Convention: Surfing the Wave .

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Division 7A revisited

Author(s):  Arthur ATHANASIOU

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Capital structuring for corporate groups

Author(s):  Gordon THRING

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Tax cases, rulings and announcements that have changed the tax landscape

Author(s):  Keith JAMES

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