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Recouping tax losses under Division 166 paper
Published on 27 May 09 by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper covers:
- the role of Division 166
- the companies to whom Division 166 applies
- how Division 166 modifies the basic continuity of ownership test
- corporate change
- the tracing concessions
- the stakeholder thresholds of the concessional tracing rules
- the no detriment rule: section 166-275
- interposition of a new entity between notional shareholders.
Author profiles
Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for 20 years and in that time has been extensively involved in advising resource companies, infrastructure projects, banks and IP intensive businesses. In recent years he has focused on contentious cross border issues, both from a litigation perspective and in alternative dispute resolution. - Current at 30 November 2020Jeannelle Menezes
Jeanelle works for Allens Arthur Robinson. - Current at 05 May 2009
This was presented at Everything There is to Know About Company Losses and Tax .
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The continuity of ownership test under Division 165
Author(s): Andrew VAN DINTER, Brian LANEMaterials from this session:
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The same business test under Division 165
Author(s): Andrew WOOLLARD, Brian LANEMaterials from this session:
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Losses and tax - The loss integrity measures
Author(s): Enzo COIAMaterials from this session:
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Recouping tax losses under Division 166
Author(s): Martin FRY, Jeanelle MENEZESMaterials from this session:
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Losses and consolidation - Entries and exits
Author(s): Duncan R C BAXTERMaterials from this session:
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