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Consolidation Intensive
Published on 18 Jul 2003 | Took place at The Sebel Lodge, Yarra Valley , VIC
Tax practitioners have in recent years discovered that the devil has been in the detail of the New Business Tax System - the loss integrity measures, the debt/equity measures and thin capitalisation measures.
Tax consolidation is the most significant tax reform measure in the last 18 years and provides a new challenge to tax practitioners - the devil is not in what the tax consolidation provisions say, it is in what they do not!
At this tax consolidation intensive the presenters provided an analysis of what the provisions say together with an understanding of what the provisions mean in managing their own or their clients' tax consolidation implementation plan.
Get a 20% discount when you buy all the items from this event.
Individual sessions
Mergers and acquisitions - due diligence
Author(s):
Tony STOLAREK
This convention paper discusses due diligence in relation to mergers and acquisitions.
Materials from this session:
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Calculating ACA Steps
Author(s):
James TARGETT
This seminar paper covers the following issues:
It focusses on over depreciation, accrued profits, mining assets and the single entity rule.
This is an updated version of a paper presented by Jim Targett at the Dawn of a New Age - Consolidations seminar held in Sydney on 18 June 2003. Click here to view that paper.
- detailed review of tax aspects
- impact of accounting standards
- possible retrospective impact on ACA
- profits/tax losses 'accruing'
- Step 3 franking and transaction
- tax losses
- plant and intangibles.Materials from this session:
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Valuation in Tax Consolidation Methodologies
Author(s):
Geoffrey SHARPE,
John JENKIN
This presentation outlines the following topics:
- interaction of entity valuation and asset valuation
- status of ATO market valuation guidelines
- treatment of goodwill
- current valuation hot issues
- ATO risk matrix
- independence
- documentation and reporting.
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Capital Allowances and ACA
Author(s):
Ronen VEXLER
This seminar paper covers the following issues:
- impact on depreciation rates and effective life
- treatment of mining rights and ex-GBE assets
- establishing the cost setting amount
- successive application of over depreciated asset adjustment on subsequent acquisition
- over depreciated asset adjustment
- market valuation requirements.
Materials from this session:
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Treatment of Trusts and Partnerships
Author(s):
Adrian O'SHANNESSY
This seminar paper covers the following issues:
- membership rules for trusts and partnerships
- specific issues for asset tax value setting
- treatment of tax losses
- leaving a group.
Materials from this session:
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Loss Integrity and Value Shifting Interface
Author(s):
Glenn DAVIES
This seminar paper covers the following issues:
- entry/formation
- during consolidation
- on leaving.
Materials from this session:
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The First Head Company Tax Return & Notifications
Author(s):
Peter COAKLEY
This presentation covers the following topics:
- what is involved in preparing a consolidation ITR
- what's changed and what it means
- the traps you need to watch out for.
Materials from this session:
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Tax Losses: Eligibility, SBT & Available Fractions
Author(s):
Richard BUCHANAN,
Greg HOWES
This presentation covers the following issues:
- transferring losses into consolidated groups
- curiosities in value and loss donation
- capital injection and non-arms length rule
- applicability of SBT to a consolidated group
- transfer of a current year loss in a non-membership period to head company
- operation of 701-30(3A) re: ownership changes at the joining time
- establishing the available fraction
- modified rules for MEC groups
- transition rules - COT losses.
Materials from this session:
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Dealing with Joint and Several Liability
Author(s):
Justin CHERRINGTON
This seminar paper covers the following topics:
- tax sharing agreements
- share sale agreements.
Materials from this session:
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Update on Critical Technical and Commercial Issues
Author(s):
Frank DRENTH
This seminar paper covers the following topics:
- what you have to do pre-consolidation
- the areas currently causing the most difficulty
- the likely longer term pitfalls?
Materials from this session:
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Exiting a Consolidated Group
Author(s):
Cameron RIDER
This seminar paper covers the following issues:
- when/how a subsidiary member exits a group
- rebuilding equity and debt cost bases on exit - the problem of amortising equity
- are the shares on capital account or revenue account?
- goodwill and other special assets
- exit history rule
- CGT and Event L5
- application of loss integrity measures on exit
- concessions for transitional groups on exit.
Materials from this session:
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Accounting for Tax Consolidation
Author(s):
Kris PEACH
This guide covers the following topics:
- the aspects of tax consolidation that have an accounting impact
- when do UIG 39 or 52 apply?
- the key requirements of UIG 39 and 52
- the key differences between the 1989 and 1999 version of AASB
- what auditors need from tax advisors to sign off on deferred tax balances.
Materials from this session:
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The Single Entity and Entry History Rules
Author(s):
Grant CATHRO
This seminar paper covers the following topics:
- inherited history rule
- implications for the characterisation of transactions
- anomalies and unresolved issues.
Materials from this session:
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Multiple Entry Consolidated Groups and their Members
Author(s):
Duncan R C BAXTER
This seminar paper covers the following topics:
- multiple entry consolidated (MEC) groups and their members
- forming a MEC group, including cost setting rules (including pooling cases) and losses
- joining an existing MEC group
- leaving a MEC group.
Materials from this session:
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