Published on 01 May 09
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper focuses on the problems that continue to affect tax losses of consolidated groups including:
- quirks in the loss transfer tests
- unrealised losses, RUNLs and LDPs - what's that all about?
- the "same business test" and the entry/exit history rules
- identifying the business of a consolidated group
- calculating and re-calculating "available fractions"
- the extra tests for re-transferred losses.
Duncan R C BAXTER
Duncan is Head of the National Tax Team at Blake Dawson. He was previously a Partner in the
International Tax Group of a global accounting firm. Earlier this year Duncan served as one of the three private
sector representatives on the Federal Government’s Tax Design Review Panel.
Current at 11 March 2009 Current at 14 May 2009
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