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SME demergers and capital returns – Is the small business restructure roll-over the answer? presentation


This presentation covers:

  • demerger
  • what is a demerger?
  • CGT - the Div 125 conditions
  • rollover - owners in head entity
  • dividend relief
  • consequences of 45B applying?
  • active assets.

Author profiles

John Middleton CTA
John Middleton, CTA is part of the ATO’s Tax Counsel Network, where he works on complex technical advice, tax reform projects, and strategic litigation. Prior to this, he had over 20 years in the private sector as Special Counsel at Clayton Utz Brisbane specialising in revenue and commercial law. He practised in CGT, stamp duty, GST and general tax. While in private practice he was listed in Doyle’s and Best Lawyers in respect of tax matters. - Current at 16 July 2020
Click here to expand/collapse more articles by John MIDDLETON.
Christine PALMER
Click here to expand/collapse more articles by Christine PALMER.


This was presented at 2018 Private Business Tax Retreat .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Structuring trusts for foreign stakeholders – It affects everyone

Author(s):  Melinda Peters,  Catherine Nufer-Barr

Materials from this session:

Ongoing use of trusts after the next election

Author(s):  Bob Deutsch

Materials from this session:

What attracts the Commissioner’s attention for private business and resolving complex issues

Author(s):  Martin Jacobs

Materials from this session:

Further details about this event:


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