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Published on 15 Feb 2001
| Took place at Swiss Grand Hotel, Bondi Beach, Sydney
The new Consolidation Regime will change the income tax landscape for all corporate groups. There are important planning issues for the acquisition or disposal of a wholly-owned entity and of particular assets. Group reorganisations, franking account planning, asset transfers and transfer of losses are all affected. This seminar ensures that you are aware of technical and practical issues under this new regime.
Get a 20% discount when you buy all the items from this event.
David J WILLIAMS
A paper discussing the background to the new consolidation regime, including: The fundamental problem; Asprey Committee recommendations; Campbell Committee recommendations; Section 80G; CGT rollover relief; Ralph Committee recommendations.
This paper consists on an overview of consolidations. It dicusses a number of issues such as: How do you become/cease to be a group?; Can I just use book values?; The end of the present grouping provisions; The end of rollovers; The proposed arms length rule; What happens to intercompany transactions after consolidation?; What happens to goodwill on consolidation?; What transition options are there? Acquiring a new company and commencing to be consolidated, what happens?; Selling a subsidiary and degrouping; How is franking account to be managed under consolidation?
Bringing Losses into a Consolidated Group on Joining
This paper looks at the issue of bringing losses into a consolidated group on joining. It discusses: Calculating and unutilised losses of a joining entity; Applying the transfer tests COT and SBT losses to the joining entity; Categorisation of transferred losses - what makes up a bundle.
This paper looks at utilising losses within a consolidated group and discusses: Loss tests to be satisfied by the Consolidated Group; Order of loss utilisationby the Head Entity; Using concessional transferred losses; Using standard transferred losses; Calculating the loss factor; When is a loss factor varied?
This paper looks at the international aspects of consolidation, including: Foreign owned groups with multiple entry holding companies - special rules; Structuring foreign investment into Australia under the consolidation regime; and how thin capitalisation, CFC and other international tax rules interact with the consolidation regime.
This paper discusses issues involved in consolidation, including: A corporate perspective; What happens if you don't consolidate?; Why you should defer/not defer consolidating groups; Are trusts able to be included in consolidated groups?; Should a holding companies and subsidiaries pay out dividends pre-consolidation?; Should companies be liquidated before consolidation commences? What is the difference between acquiring assets or acquiring shares in a target, under the consolidation regime?
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