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