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Context and carve-outs paper
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 05 May 2009
This was presented at The New Modified Loss Recoupment Rules .
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Context and carve-outs
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