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Division 250 presentation


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.

Author profiles

Michael Cox
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
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Brian Lawrence
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
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This was presented at 6th Annual Property Intensive .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Division 250

Author(s):  Brian LAWRENCE,  Michael COX

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