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