shopping_cart

Your shopping cart is empty

  • Home
  • How can Section 974-80 be fixed paper?

How can Section 974-80 be fixed paper?

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is 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.

Published on 11 Feb 10 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • application of Section 974-80
  • the funding requirement
  • identifying an effective equity interest
  • debt test override.

Author profile

Lawrence Magid CTA
Larry has been a Tax Partner at Allens for over 30 years. He specialises in corporate and international taxation including, in particular, financing issues, capital raising and company distributions. He has represented the Law Council of Australia in consultations with government on Part IVA (as well as on the NTLG Finance & Investment Subcommittee) and was a member of the Roundtable which advised Treasury on the amendments made to Part IVA in 2013. He was also a member of the Board of Taxation working group which conducted the post-implementation review of Div 974. - Current at 08 March 2016
Click here to expand/collapse more articles by Larry MAGID.

 

This was presented at 2010 Financial Services Taxation Conference .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Deferred purchase agreements, instalment warrants and protected loans

Author(s):  Tim KYLE

Materials from this session:

Preference shares and nonshare equity

Author(s):  Monica JORDAN

Materials from this session:

Sovereign investment in the financial services sector

Author(s):  Steven ECONOMIDES,  Steve O'CONNOR

Materials from this session:

St George Bank case update

Author(s):  Deborah HASTINGS

Materials from this session:

St George Bank Ltd and the cost of structure capital

Author(s):  AH (Tony) SLATER

Materials from this session:

Product rationalisation

Author(s):  Tony MULVENEY,  Bernard FINNEGAN,  Louisa VAN

Materials from this session:

Reforms to Australia's foreign source income anti-tax-deferral regimes

Author(s):  Haydn DAW

Materials from this session:

Australia as a financial centre: Building on our strengths

Author(s):  Jeremy DUFFIELD

Materials from this session:

The MIT review - What's in it for you?

Author(s):  Karen PAYNE

Materials from this session:

Islamic finance: The path to tax neutrality

Author(s):  Richard BUCHANAN

Materials from this session:

Proposed R&D tax credits - Credit where credit is due

Author(s):  Serg DUCHINI,  Sukvinder HEYER

Materials from this session:

The Obama tax reform proposals

Author(s):  Chris MORRIS,  D SNOWDEN

Materials from this session:

Tax accounting issues affecting the financial services industry

Author(s):  David L WILLIAMS,  Stef MASON

Materials from this session:

Infrastructure - incentives and PPP financing structures

Author(s):  Steve FORD

Materials from this session:

Division 230 and equity interests

Author(s):  Euan CAMPBELL

Materials from this session:

Division 974 and limited recourse debt

Author(s):  Euan CAMPBELL

Materials from this session:

How can section 974-80 be fixed?

Author(s):  Larry MAGID

Materials from this session:

Paragraph 177EA(17)(ga)

Author(s):  Peter WALMSLEY

Materials from this session:

Further details about this event:

 

Copyright Statement
click to expand/collapse