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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
Hayden is a Director of Greenwoods & Freehills Pty Limited. He advises listed entities in the energy & resources and financial services industries on income tax issues raised in M&A, funding, special project and general corporate tax matters. His areas of interest and expertise include the taxation of financial arrangements (all four tranches) and tax consolidation. Hayden is a member of the NTLG Finance & Investment Subcommittee and it’s TOFA Working Party. He also chairs the Taxation Institute’s Education Committee (Victoria). Hayden frequently presents and is regularly published on corporate income tax matters.
Current at 9 February 2009 Current at 14 May 2009 Click here to expand/collapse more articles by Hayden SCOTT.


Individual sessions

Tax black holes

Author(s):  Hayden SCOTT

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