Skip to main content
shopping_cart

Your shopping cart is empty

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
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 Click here to expand/collapse more articles by Andrew WOOLLARD.
 

 

This was presented at The New Modified Loss Recoupment Rules .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Using the modified 'substantial continuity of ownership' test

Author(s):  Andrew WOOLLARD

Materials from this session:


Further details about this event:

 

Copyright Statement
click to expand/collapse