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The three Ds: debt equity, debt forgiveness and Division 7A paper

The three Ds: debt equity, debt forgiveness and Division 7A paper

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DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 16 Feb 06 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This paper:

seeks to put each of the 3Ds in context by considering their objective
provides a refresher as to the operation of each of these statutory regimes
examines aspects of the practical application of each of the 3Ds.

Author profile

Leonard Hertzman CTA

Len Hertzman, CTAis an Assistant Commissioner in the ATO’s Tax Counsel Network and is based in Perth. He was previously a tax partner at Ashurst. Len is also a National and State Councillor of The Tax Institute and former chair of the National Tax Convention and National Resources Tax Conference program committees. - Current at 05 April 2019

More by Len HERTZMAN

Stamp duty and resources transactions paper - 18-October-2013
A super tax no more - agreed principles for Australia's resource rent tax arrangements. - 22-July-2010
From the eye of the storm - Tax issues for entities nearing, or in insolvency paper - 04-March-2010
Debt restructuring: from initial sniffles to the last gasp paper - 13-August-2009
White paper: tax treatment of carbon pollution permits. - 11-February-2009
The government's taxation of climate change - beyond the acronyms. - 21-August-2008
ETS : is it just another word for "tax"? - 17-July-2008
Member profile - 01-December-2007
Australian CGT and foreign residents: giving with one hand and taking with another. - 01-November-2006
Taxing advantage of Demerger Relief - 01-June-2003
Formation of the trust - 12-October-2001

Click here to expand/collapse more articles by Len HERTZMAN.

This was presented at Loans and Financial Arrangements: Principles, Problems and Practical Examples .

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Individual sessions

General principles relating to the deductibility of interest

Author(s): Stephen BARKOCZY

Materials from this session:

General principles relating to the deductibility of interest paper

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Interest deductibility and timing issues presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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