The other end of the food chain - Consolidation and Exits: summary charts

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Published on 01 Aug 04 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

This article highlights and summarises some important disparities between the consolidation 'entry' and 'exit' calculations and the implications of consolidation on structuring a disposal as an asset or entity sale. For a detailed analysis of these issues see the August and October 2004 editions of The Tax Specialist.

Author profiles

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 02 November 2016

More by Hayden SCOTT

Alternative assets insights: Alternative asset classes and flow-through taxation - 01-October-2015
Applying infrastructure tax concepts to different industries paper - 27-August-2015
Win your privatisation bid for infrastructure assets by optimising capital allowances paper - 18-March-2015
Negative control - 01-November-2014
M&A: Financing paper - 06-September-2012
The heart of corporate tax: Consolidation paper - 25-October-2010
TOFA 3&4 : what now? - 15-January-2009
TOFA Stages 3 and 4 - the marathon enters final phase. - 07-January-2009
Some naughty tax distributions paper - 16-February-2007
Final TOFA reform set for 1 July 2007? - 25-January-2007
TOFA hits the road: Div 230 and City Link (Pt 2). - 22-August-2006
TOFA hits the road: Div 230 and City Link (Pt 1). - 17-August-2006
Depreciation rates to increase by 25%. - 18-May-2006
The new company loss recoupment rules. - 30-September-2005
Consolidation and Exits - the other end of the food chain - 01-October-2004
Consolidation and Exits - the other end of the food chain Part I - 01-August-2004

Click here to expand/collapse more articles by Hayden SCOTT.

Kenneth Spence CTA-Life

Ken is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute. - Current at 25 May 2017

More by Ken SPENCE

Consolidations – Where is it all up to and what does it mean? paper - 26-October-2016
The evolution of corporate taxation – A work in progress - 01-October-2016
The evolution of corporate taxation - A work in progress paper - 02-March-2016
Surgery with anaesthetics: mergers and acquisitions taxation - 01-June-2015
M&A taxation: Roasting old chestnuts paper - 18-March-2015
Tax consolidation – Practical issues in the current law paper - 09-October-2014
Corporate M&A - Implications of the new consolidation changes paper - 14-March-2012
Consolidation developments: The use of “tax cost setting amount” – The never-ending saga paper - 10-February-2011
Tax consolidations: Issues for late adopters and SMEs paper - 15-October-2010
Preliminary analysis of The Board of Taxation position paper "post implementation review into certain aspects of the consolidation regime" paper - 14-October-2010
Legislative changes – ACA related amendments paper - 08-May-2009
Consolidation: Legislative changes (Part A) – ACA related amendments paper - 01-May-2009
Tax consolidation for corporate groups - Examples with solutions paper - 02-April-2009
Tax Consolidation For Corporate Groups - Examples with solutions paper - 02-April-2009
Tax treatment of liabilities – The unexplored parallel universe paper - 12-March-2009
Tax consolidations for corporate groups–“Getting on board” paper - 28-November-2008
Consolidation - round table discussion paper - 12-October-2007
Editorial message: Tax consolidation — sharpening a cutting-edge reform - 01-August-2007
Tax consolidation — Government announcements yet to be legislated - 01-August-2007
New CGT exposures and exemptions for non-residents paper - 17-March-2007
The pending taxation of financial arrangements regime - practical analysis paper - 06-October-2006
Capital gains has narrower scope but longer arm. - 01-September-2006
'Strange but true': Corporate acquisition and disposal nuances in the new consolidation world paper - 25-August-2006
Re-targeting capital gains tax for non-residents:Proposed Division 855 - 'Winners and Losers' - 01-August-2006
Tax advisings in practice - where is the line to be drawn and how do you draw it? paper - 06-October-2005
It's important to start by getting your As and Bs right: capital benefit schemes paper - 17-March-2005
Consolidation and Exits - the other end of the food chain - 01-October-2004
Consolidation and Exits - the other end of the food chain Part I - 01-August-2004
Consolidation for SMEs convention paper - 18-October-2003
The New World of Consolidation: Overview of Commercial and Technical Implications seminar paper - 11-June-2003
Business consolidations for tax effectiveness - 17-May-2002
Consolidations: large business - 14-March-2002
Implications of the Entity Tax and Consolidation RBT Changes - 01-December-2000
Implications of the Entity Tax & Consolidations RBT Change - 09-November-2000
Corporate tax in transition - 18-April-2000
Scrip-for-scrip roll-over relief : "a great idea but..." - 21-March-2000
The Ralph Report: Specific corporate and trust group issues: consolidations and losses - 01-November-1999
Tax Losses & Consolidations Workshop - 27-October-1999
Taxation of corporate groups and corporate losses: workshop questions and notes - 27-October-1999
The big picture: does tax reform mean existing business structures are now inappropriate? - 09-September-1999
Approaching the rapids - corporate tax "reform" proposals - 24-March-1999
Business tax reform - 26-February-1999
Issues and agendas - 01-December-1998
Mergers, acquisitions and reconstructions - 12-November-1998
Tax reform - where are we now and where are we going? - 16-October-1998
CGT: a journey of discovery - 01-June-1998
Capital gains tax: the TLIP rewrite - 01-June-1998
An ace up whose sleeve?: the 1998 Federal Budget: issues that are emerging - 29-May-1998
The 1998 Federal Budget - 15-May-1998
Issues and agendas - 01-May-1998
Issues and agendas - 01-April-1998
Capital Gains Tax TLIP Rewrite: Part II - 28-October-1997
Tax in review: Painting over the cracks - 01-September-1997
The CGT rewrite - a breakthrough - 29-August-1997
The CGT rewrite a breakthrough - 27-August-1997
Corporate structure and reorganisation - 30-May-1997
Budget accessories - 1996 Budget announcement of relevance to corporates - 14-November-1996
Out of the red: Corporate grouping: For richer or poorer, better or worse ; Tax practice: The remedies of administrative law - 01-October-1996
Out of the red : Commercial debt : unforgiven implications - 01-May-1996
Commercial debt : unforgiven implications - 01-April-1996
Commercial debt: unforgiven implications - 01-April-1996
Corporate tax developments - will they ever end? - 08-March-1996
Annual update : a review of important legislative changes, tax cases and rulings - 28-September-1995
Capital gains tax - corporations law amendments - 01-June-1995
Fool's gold - the new share value shifting provisions - 17-May-1995
How Long Is The Fuse and How Big is the Bomb? - A Review of Section 160ZZT - 01-December-1994
Offshore perspectives: your client's tax horizons. Part 4: a foreign partner or parent - 01-April-1994
Offshore perspectives: your client's tax horizons. Part 2: working abroad - tax issues for individuals - 01-February-1994
Offshore perspective: your client's tax horizons. Part 1: foreign portfolio investments - 01-December-1993
Dealing at arm's length - the Commissioner shows his hand - 01-January-1993
Limitations on the transfer of capital losses - 01-January-1990
Self-assessment - current state of play - 01-January-1990
Effective remuneration planning - 01-January-1989
Fringe benefits remuneration restructuring - 01-January-1986

Click here to expand/collapse more articles by Ken SPENCE.

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