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Specific dealings with ‘impaired’ debts paper

Published on 06 Nov 08

This paper covers:

  • when can you write-off a debt as a bad debt?
  • originated debts
  • purchased debts
  • recapitalisation of any entity
  • recourse debt vs limited recourse debt (including events of default).
This paper also considers the implications for borrowers, lenders and refinanciers in respect of:
  • Section 6-5
  • Section 8-1
  • CGT provisions (including value shifting)
  • commercial debt forgiveness
  • traditional and qualifying security provisions
  • impact on carried forward losses
  • share capital tainting.

 

Author profile

Joshua Cardwell CTA
Photo of author, Joshua CARDWELL Josh Cardwell, Joshua Cardwell CTA, joined PwC in 2013 as the Head of Real Estate Tax. Prior to joining PwC, Josh was a Director and Head of M&A at Greenwoods & Freehills and was previously a Partner at Deloitte. Josh has over 23 years taxation experience with a focus on the real estate funds sector and has been involved in many iconic transactions across industries. His current practice is primarily focussed on inbound, outbound and domestic real estate clients, including providing advice related to fund establishments, distribution matters, stapled structures and other matters specific to listed and unlisted property groups. Josh is a long standing member of the Property Council of Australia's Income Tax Committee, holds a Master of Taxation from the University of Sydney, a Bachelor of Business from the University of Technology Sydney, is a Chartered Accountant, Tax Agent and a Chartered Tax Adviser. - Current at 12 February 2019
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This was presented at Tax in an Uncertain Economy .

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Individual sessions






The perspective of the appointed representative

Author(s):  Barry KOGAN

Materials from this session:






Further details about this event:

 

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