Making the most of limited resources in tax due diligence
Normally due diligence is carried out where a consolidated group is acquiring another consolidated group or a stand alone entity or group of entities - are you looking at the most significant matters or are the entities being acquired bringing unrecognised problems into the group? This paper covers topics including:
joint and several liability exposure arising from membership of previous consolidated groups - lack of visibility
risks from open assessment periods beyond four years
latent tax liabilities which could be triggered on acquisition, for example
CGT events L3, L5 and J1
crystalisation of unrealised gains
limitations on availability and utilisation of tax attributes
changes in relative market values of group companies
impact of gearing on available fraction calculations
capital injection and other adjustments
structural tax issues for the carry-forward entity arising from historical positions.
ROSA: not just a pretty name - managing compliance post ROSA
This paper examines the effect of the recent legislative changes to assessments, amendments, rulings and penalties and how they impact on the way tax advisers and tax managers should be managing compliance obligations including:
overview of the new rules for assessments, amendments and rulings including Part IVA amendment periods
are you really now protected if you have a loss or no assessment?
how do you ensure that you’re covered? When and what you have as a private ruling - tips and traps
is there any value in oral rulings?
what constitutes a public ruling and how much can you now rely on them?
the new penalty regime - GIC, SIC and the ATO’s new practice statement.