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Liabilities - A changing world post TOFA presentation

Published on 19 Feb 14 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • pre-TOFA treatment of liabilities
  • TOFA treatment of liabilities
  • example 1 – Historic rate rollover
  • example 2 - Securitisation
  • example 3 – Accounting Provision and FRE9
  • example 4 – Fair value assets and liabilities
  • example 5 – Buying back debt
  • example 6 – Waiver/release of debt
  • example 7 – FX on equity interests
  • TOFA/consolidation Interactions
  • liabilities example – the 2012 changes.

Author profiles:

Euan CAMPBELL

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Andrew Hirst
Andrew Hirst is a Senior Associate in the Sydney office of Greenwoods & Freehills Pty Limited. Andrew joined Greenwoods & Freehills Pty Limited in January 2004. He advises on a wide range of corporate and banking related tax issues with particular focus on international structures and financial transactions. Andrew has particular experience in the structuring of inbound and outbound investments, cross border transactions and general international tax issues. In particular, Andrew has advised on a range of transactions in the corporate and banking spheres including the structuring of offshore groups and investments, the raising and provision of capital across jurisdictions, stapling arrangements, securitisations and other tax-based financial transactions. Andrew advises a wide range of clients including banks, large corporations, stapled groups and listed property trusts. Prior to moving to Sydney and joining Greenwoods & Freehills, Andrew was a senior tax lawyer in a major London law firm. During his eight years in London, Andrew gained extensive experience in the structuring and implementation of large domestic and international transactions.
Current at 23 August 2007
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This was presented at 2014 Financial Services Taxation Conference .

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FATCA - What is the state of play?

Author(s):  William BROWN

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Liabilities – A changing world post TOFA

Author(s):  Euan CAMPBELL,  Andrew Hirst

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