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Loss Recoupment Tests presentation

Published on 10 Jul 03 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation examines:
- the loss recoupment rules
- practical problems in establishing continuity of ownership
- the restrictiveness of the same share same owner test
- the danger of relying on the same business test
- the anti-avoidance provisions that need to be taken into account when considering whether losses can be recouped?

Author profiles:

Susan Franks CTA
Susan is a Tax Principal at Deloitte Touche Tohmatsu. She advises large corporate groups about the acquisition/disposal of businesses, liquidating entities, investing in/out of Australian, thin capitalisation and compliance issues. Current at 15 September 2004 Click here to expand/collapse more articles by Susan FRANKS.
 
Matthew Turner
Matt is a tax partner in Deloitte’s corporate and international tax group in Sydney with a focus on private equity clients. Matt has over 10 years of experience in both local and international aspects of company taxation with particular focus on tax consolidation, debt/equity rules and capital gains tax. He has applied his skills to assist clients with transactions including: private equity acquisitions and disposals of Australian investees, cross border financing instruments, trans-Tasman investment structures, corporate demergers, post-acquisition transition work including tax consolidation and securitisation of assets. Current at 09 September 2007
Individual sessions

Loss Recoupment Tests

Author(s):  Susan FRANKS,  Matthew TURNER

Materials from this session:

Further details about this event:

 

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