Often in preparing an entity for sale, a level of restructuring needs to occur. Some of the things that are often contemplated are writing off loans, using the consolidations regime to facilitate moving assets, undertaking share buy-backs, and issuing dividend access shares, amongst other ideas. Some of these ideas work well, and some do not. This paper considers the taxation implications of decisions that need to be made when 'cleaning up' an entity to facilitate a sale.
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