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 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
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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