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Section 45B under a microscope — Capital repayments

Published on 01 Oct 06 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Section 45B is arguably highly over-engineered, reflects an overreaction to perceived preferentially taxed returns of share capital, and applies to a vast array of major business transactions; including, for example, share buyback arrangements and demerger transactions.

Author profiles:

Jock McCormack CTA
Jock McCormack, DLA Piper, is a leading Sydney-based international taxation lawyer with specific expertise in income tax and more than 30 years experience managing complex tax matters. Jock's major areas of expertise include debt and equity structuring, acquisitions/mergers/divestments, international tax including transfer pricing, capital gains tax and major projects taxation issues. Jock also advises various major corporations on ATO tax audits, tax strategy reviews, litigation and related issues including managing, negotiating and settling challenging and contentious tax issues and reviews. Current at 24 November 2014 Click here to expand/collapse more articles by Jock MCCORMACK.
 
Anshu MAHARAJ
Anshu is a Senior Associate with Phillips Fox Lawyers.
Current at October 2006
Click here to expand/collapse more articles by Anshu MAHARAJ.
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