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Less than the sum of the parts: Tax losses of consolidated groups paper

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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.

Author profile

Duncan Baxter
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
Click here to expand/collapse more articles by Duncan R C BAXTER.

 

This was presented at 4th National Consolidation Symposium .

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Less than the sum of the parts: Tax losses of consolidated groups

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