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Tax black holes presentation


Specific issues considered in this presentation include:

  • when is a lease termination payment deductible over five years?
  • how has depreciation's concept of cost been expanded?
  • how has CGT's concept of cost base, particularly the 4th element, been expanded?
  • what are the choke points in section 40-880, for example:
    • what exactly is ‘expenditure’, and precisely when is it ‘incurred’?
    • can preliminary expenditure be anything other than of a capital nature?
    • how do the multiple levels of apportionment in section 40-880 integrate?
    • how flexible is the concept of ‘in relation to’?
    • what is the significance of ‘other’ rights and the preservation of goodwill?
  • managing the host of related M&A interactions

Author profile

Hayden Scott FTI
Hayden, FTI, is a Partner at PwC in their Tax & Legal practice. He has over twenty years of experience in the tax environments of the Big 4, top-tier law firms, and Government (both Treasury and ATO). Hayden extensively advises clients in the financial services and infrastructure industries, as well as extensively advising outside those industries on finance tax matters. Additionally, Hayden is a contributor to the broader tax policy and reform conversation, having been a member of the (now defunct) National Tax Liaison Group Finance and Investment Subcommittee, and, more recently, an expert panellist on the Board of Taxation’s review of the debt-equity rules. - Current at 17 March 2016
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Tax black holes

Author(s):  Hayden SCOTT

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