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Using the modified 'substantial continuity of ownership' test presentation

Published on 12 Oct 05 by VICTORIAN DIVISION, THE TAX INSTITUTE

This presentation covers:

  • Eligibility - what is a 'widely held' or 'eligible Div 166 company'?
  • How the modified tracing rules apply in relation to:
    • directly and indirectly held interests of less than 10%
    • deemed beneficial owners
    • the loss integrity and unrealised loss rules
    • bad debts claims
    • net capital losses
  • Ultimate owners
    • family trusts
    • Governments
  • Testing for preference shares and shares with varying rights
  • When testing must occur?
    • the basic rule
    • loss companies coming into existence in the loss year
    • applying prior year capital losses
    • current year losses.

Author profile:

Andrew Woollard CTA
Andrew Woollard FTIA is a Tax Partner with Ernst & Young, specialising in corporate and international tax. Andrew has over 15 years experience in advising clients on a broad range of corporate tax issues, including M&A transactions, restructuring, and business tax reform issues, including tax consolidation and tax loss issues. Current at 03 September 2010 Click here to expand/collapse more articles by Andrew WOOLLARD.
 

This was presented at The New Modified Loss Recoupment Rules.

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Using the modified 'substantial continuity of ownership' test

Author(s):  Andrew WOOLLARD

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