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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 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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Individual sessions

Using the modified 'substantial continuity of ownership' test

Author(s):  Andrew WOOLLARD

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