A joint submission by the Institute of Chartered Accountants in Australia, CPA Australia, the Taxation Institute of Australia and the Corporate Tax Association of Australia regarding TD 2004/D21 Income tax: consolidation: capital gains: does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 mean that section 124-784 does not apply to the consolidated group in relation to shares issued by a subsidiary member to the head company under a scrip-for-scrip arrangement?