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
- 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.
Andrew is a Tax Partner with Ernst & Young, working in corporate and international tax. Andrew has worked extensively with corporate groups with significant tax losses. This work has included ATO tax loss audit activity, continuity of ownership testing, same business testing, loss integrity impacts, as well as the impacts of the tax consolidation regime on tax losses when forming a consolidated group or as part of post consolidation M&A activity.
Current at 26 September 2007 Current at 26 September 2007
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