Miscellaneous 2009

M&A and consolidation: New restructure rules

Source: National

Published Date: 1 May 2009

 

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This paper covers:

  • background - what was at stake and what was the concern?
  • what the recent amendments seek to achieve
  • the start date for the amendments
  • the threshold test - "restructure"
  • the impact of the amendments on cost base
  • the replacement entity's choice to deny roll-over relief
  • the "stick" option for the target's assets
  • a worked example of the cost base outcomes in a tax consolidation context
  • scrip-for-scrip acquisitions - the new tax landscape
  • a restructure which meets the requirements of Subdivision 124-G
  • a restructure using CGT rollover under Subdivision 124-M involving a non-widely held target and acquiring company
  • a restructure using CGT rollover under Subdivision 124-M involving a widely held target or acquiring company
  • non-restructure using CGT rollover under Subdivision 124-M.

Individual Session

M&A and consolidation: New restructure rules

Author(s): Richard Hendriks , Chris Gibbs

Details

  • Published By: Richard Hendriks
  • Published On:1 May 2009
  • Took place at:Sheraton on the Park, Sydney

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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Miscellaneous 2009

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