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Share capital tainting paper

Published on 26 Oct 06 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

What flows from the Tax Laws Amendment (2006 Measures No 3) Bill 2006, introduced into the House of Representatives on 25 May 2006? This paper covers topics including:

  • what is share capital account tainting and where has it been?
  • what consequences does tainting share capital have for companies and their shareholders?
  • share capital account tainting and AIFRS - do we have a resolution for this risk?
  • how does share capital account tainting interact with tax consolidation?
  • what do these provisions mean for share based payment transactions?

Author profile:

Richard Buchanan FTI-Life
Richard is a Corporate Tax Partner with Deloitte Touche Tohmatsu. He specialises in advising major corporates on the tax implications of major transactions such as mergers and acquisitions, divestments, restructures and IPOs. Richard also has experience in advising corporates on implementing both A-IFRS and tax consolidation. Richard is a member of the NTLG IFRS subcommittee and the ICAA IFRS subcommittee and has been heavily involved in the consultation with respect to the development of the share capital tainting provisions. Current at 11 September 2006 Click here to expand/collapse more articles by Richard BUCHANAN.
 

This was presented at Annual Corporate Tax Intensive.

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