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M&A and consolidation: New restructure rules paper

Published on 01 May 09 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • background - what was at stake and what was the concern?
  • what the recent amendments seek to achieve
  • the start date for the amendments
  • the threshold test - "restructure"
  • the impact of the amendments on cost base
  • the replacement entity's choice to deny roll-over relief
  • the "stick" option for the target's assets
  • a worked example of the cost base outcomes in a tax consolidation context
  • scrip-for-scrip acquisitions - the new tax landscape
  • a restructure which meets the requirements of Subdivision 124-G
  • a restructure using CGT rollover under Subdivision 124-M involving a non-widely held target and acquiring company
  • a restructure using CGT rollover under Subdivision 124-M involving a widely held target or acquiring company
  • non-restructure using CGT rollover under Subdivision 124-M.

Author profile:

Richard HENDRIKS

Click here to expand/collapse more articles by Richard HENDRIKS.
 

This was presented at 4th National Consolidation Symposium .

Get a 20% discount when you buy all the items from this event.

Individual sessions

ATO perspective on consolidation - Unravelling the mysteries of the single entity rule

Author(s):  Des MALONEY,  Peter WALMSLEY

Materials from this session:






Consolidation: Legislative changes (Part B)

Author(s):  Peter MURRAY

Materials from this session:

Consolidation and mining assets – Some selected acquisition issues checklist

Author(s):  Cameron RIDER

Materials from this session:


Tax consolidation – Financial services

Author(s):  Tony STOLAREK

Materials from this session:



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