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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 2020
Click here to expand/collapse more articles by Martin FRY.
Jeannelle Menezes
Jeanelle works for Allens Arthur Robinson. - Current at 05 May 2009
Click here to expand/collapse more articles by Jeanelle MENEZES.

 

This was presented at Everything There is to Know About Company Losses and Tax .

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