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Mergers and acquistions in a post-consolidation world presentation

Published on 16 Feb 06 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This presentation examines the following topical issues affecting M & A transactions involving tax consolidated groups:

  • the effect of an SBT ceiling on the ability of a bidder to acquire the carry-forward losses of a target entity
  • the effect of an SBT ceiling on the ability of a bidder to claim bad debt deductions for debts "inherited" from a target entity
  • the characterisation of the sale of membership interests in subsidiary members, particulary in having regard to the quantum of capital losses currently existing in the tax system
  • whether a consolidated group will be denied a loss on the sale of a loss-making subsidiary member , if the subsidiary member is sold to another consolidated group

Author profile:

Martin FRY

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This was presented at 2006 Financial Services Taxation Conference: From every angle .

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