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How can Section 974-80 be fixed paper?

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.

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