Published on 15 Jun 04
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper looks at possible ownership structures that can be set up to maximise the flexibility for income redistribution within corporate groups. How should a business handle the many trade-offs - for example in trusts, the trade-off between flexibility and loss quarantining.
Part of this paper looks at the enactment of the so-called simplified imputation system which changed the position of companies - they now become both users as well as transmitters of franking credits. This paper looks at how the imputation system affects the ability of companies to pass income through chains of companies and other vehicles. It focusses especially on the recent amendments and new rules about losses arising from unusable franking credits.
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