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Tax Black Holes for Corporate Groups

Published on 21 Nov 2006 | Took place at RACV Club, Melbourne , VIC

These seminar materials consider the technical and practical aspects of the line, recently redrawn, between expenditure that receives income tax recognition and expenditure which continues to enter an income tax black hole.

Individual sessions

Tax black holes

Author(s):  Hayden SCOTT

Specific issues considered in this presentation include:

  • when is a lease termination payment deductible over five years?
  • how has depreciation's concept of cost been expanded?
  • how has CGT's concept of cost base, particularly the 4th element, been expanded?
  • what are the choke points in section 40-880, for example:
    • what exactly is ‘expenditure’, and precisely when is it ‘incurred’?
    • can preliminary expenditure be anything other than of a capital nature?
    • how do the multiple levels of apportionment in section 40-880 integrate?
    • how flexible is the concept of ‘in relation to’?
    • what is the significance of ‘other’ rights and the preservation of goodwill?
  • managing the host of related M&A interactions
Materials from this session: