Published on 22 Feb 05
by VICTORIAN DIVISION, THE TAX INSTITUTE
Issues covered in this presentation include:
- when does an entity exit? - special issues on liquidation and for MEC groups
- a CGT event L5 if liabilities exceed the tax cost of assets - a problem with insolvent subsidiaries
- assets which may not have a cost base on exit
- what is the tax value of intra-group assets and liabilities when an entity leaves a group?
- issues with merged and split assets and goodwill
- issues with liabilities and the impact of IFRS, the interaction between s711-45(3) and (5)
- if Division 149 applies after the formation of a group, what is its effect on the disposal of a subsidiary member with a pre-CGT factor?
- when is the gain or loss of the head company on the disposal of membership interests
- in subsidiary member on revenue or capital account.
This was also presented by Paul Abbey at the Tax Consolidation seminar held in Sydney on 22 February 2005.
David is a tax partner with PricewaterhouseCoopers. He was involved in the Government consultations which led to formulation of the original tax consolidation proposal and has maintained a significant involvement ever since, assisting clients with implementation and ongoing issues and participating in the NTLG Consolidation Sub Committee and various of its issue specific working groups.
Current at 9 February 2009 Current at 15 May 2009
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