Published on 13 Feb 13
by NATIONAL DIVISION, THE TAX INSTITUTE
A technical paper examining the tricks and traps of the integrity rules for realised losses, unrealised losses and bad debts, including:
- continuity of ownership and same business test developments
- writing off bad debts and the Commissioner’s discretion
- tax consolidation interactions and modifications
- recent ATO activity
- new developments, including loss carryback rules and the low value asset threshold announcement.
Julian Humphrey CTA
Julian, CTA, is a Partner of KPMG’s Banking and Finance practice with over 18 years experience. He works primarily with international banks and financial services companies operating in Australia, providing corporate income tax and more recently transfer pricing services. Julian’s areas of expertise include the taxation of banks and bank branches, the taxation of financial arrangements and retail financial products as well as Australia’s offshore banking regime. He has advised on a number of major M&A transactions in the financial services sector in recent years.
He is currently heavily involved in the base erosion and profit shifting debate, working with clients to implement country-by-country reporting. He is a regular participant in consultation with
the government on Australia’s tax reform proposals affecting Australian financial institutions. Current at 17 March 2016
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