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Allocable Cost Amount - Steps 2, 3 & 4 seminar paper


The issues covered in this seminar paper include:
- what liabilities are
- dealing with linked liabilities, and off-balance sheet liabilities
- allowing for present or future tax deductions
- issues relating to intercompany debts
- allowing for unrealised gains and losses
- debt/equity issues
- finance and operating leases
- provision for taxes and deferred tax liabilities
- discharge of liabilities and CGT event L7
- transitional treatment of unfrankable undistributable profits
- profits accruing to a group in a creeping takeover
- intragroup dividends and their impact on step 3
- profits which recoup losses.

Author profile

Anthony Stolarek
Photo of author, Tony STOLAREK Tony engages with Australia's federal and state governments, Treasury and Taxation Office on tax policy and tax administration, through the EY Australia Tax Centre for Excellence. In his EY role and membership of the Institute of Chartered Accountants in Australia tax technical committee, he is heavily involved in submissions to government and the ATO on policy proposals, changes in the tax system and improving its administration and interpretation. Tony is an ICAA representative on the ATO National Tax Liaison Committee and various subcommittees and a member of the Law Council of Australia Business Law tax committee. He is also involved in the EY global Tax Policy Services network which has had significant focus on Base Erosion and Profit shifting in the last year. Tony is a member of the Treasury Special Reference Group relating to its scoping paper dealing with the Risks to Sustainability of the Corporate Tax Base. - Current at 14 August 2013
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