Context and carve-outs paper

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Published on 12 Oct 05 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

historical and legislative context to the modified COT
the objects clause
concessional effect
the 'corporate change' rule
other carve-outs:

minimum interests rule
controlled companies
different notional shareholders
general modifying rules

application dates and elections.

Author profile

Duncan Baxter

Duncan is a Partner at Blake Dawson. He was previously a Partner in the International Tax Group of a global accounting firm. Duncan served as one of the three private sector representatives on the Federal Government’s Tax Design Review Panel. - Current at 23 January 2017

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Click here to expand/collapse more articles by Duncan R C BAXTER.

This was presented at The New Modified Loss Recoupment Rules .

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Using the modified 'substantial continuity of ownership' test

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Context and carve-outs

Author(s): Duncan R C BAXTER

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Context and carve-outs paper
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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The New Modified Loss Recoupment Rules

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