Published on 22 Jul 04
by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper covers the following topics:
- tax outcomes on exit of subsidiary from a consolidated group
- timing and characterisation of exit
- calculation of old group's allocable cost amount
- treatment of tax attributes
- CGT event L5
- is an asset sale an alternative.
This paper was also presented by Chris Gibbs at the Consolidation: M&A Experiences seminar held in Sydney on 28 July 2004.
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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