Author(s): John W DE WIJN This seminar papers discusses interest deductibility, with a focus on the following issues: What is debt as opposed to equity – the traditional approach; The critical tests in determining deductibility of interest; When does interest start and cease to be deductible?; Issues arising on intra group lending; The importance of purpose – do we need to now look at the advisor's role?
Author(s): Robert DEUTSCH This seminar paper discusses thin capitalisation with a focus on: A point-by-point plan to understanding the new rules; The eight categories; The formula for each of the eight categories; Key concepts: understanding and problems; Conclusions: going forward – dealing effectively with the detailed application of the rules.
Author(s): Michael BERSTEN This powerpoint presentation is an overview themes discusses by the Part IVA discusion panel at the 9th Annual Tax Intensive. Topics covered include: Part IVA in court cases; protection for taxpayers and advisers; and applying part IVA to tax effective investments.
Also included in this download is the reading material distributed for this session.