Published on 27 Aug 08
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
Division 250 had a difficult birth and is proving to be a troublesome infant. The law is derived from anti-avoidance issues connected with dealing with tax exempt state government entities but it now has an impact on ordinary, commercial real estate transactions. This presentation considers some of the practical difficulties and unresolved issues arising from the application of Division 250, including:
- the impact of financing multiple properties with single debt facility
- what is the most appropriate measure of expected financial benefits?
- how to calculate the value of a building at the end of an arrangement
- whether it is appropriate to apply Division 250 to foreign property held through a foreign entity
- the impact of borrowing from an offshore financial institution on the limited recourse debt test.
Michael advises clients on designing and operating their tax
reporting and compliance processes through a combination of
strategy, people, processes and technology. In this role Michael
has lead a series of Tax Data Academies designed to equip tax
professionals with skills needed to operate in the tax function
of the future. He has firsthand, practical experience in building
and managing offshore delivery centres, deploying a variety
of technology solutions both for both PwC and its clients, as
well as over 10 years of experience in providing domestic and
international tax advice.
- Current at
02 December 2017
Brian Lawrence FTIA is a Partner with PricewaterhouseCoopers. He has specialised in corporate tax for over 20 years and has been involved in many corporate activities including mergers, acquisitions and Initial Public Offerings. Main client responsibilities include property companies, property trusts, property developers, banks, financial institutions and funds management activities. Clients include major Australian corporate groups. Brian has extensive experience advising on real estate tax matters including IPOs for a significant number of listed property trusts and property syndicates, sale and leasebacks and the establishment of numerous funds and stapled structures. He also has extensive experience in performing tax due diligence work on acquisitions.
- Current at
27 August 2008