ITAA 1997 s 974-20

Income tax: can the assignment of an intra-group debt or income stream to an entity that is not a member of the consolidated group give rise to a debt interest for the head company of the group under Division 974 of the Income Tax Assessment Act 1997?

Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an 'effectively non-contingent obligation' to provide 'financial benefits' as interest payments from the time that a change in the interest rate could take effect?

Income tax: application of section 177EA of the Income Tax Assessment Act 1936 to non-share distributions on certain 'dollar value' convertible notes

Income tax: issue of CPS2 by Suncorp Group Limited

Income tax: issue of convertible preference shares (CPS3) by Suncorp Group Limited

Division 974 - non share equity interests

Redeemable preference shares: interaction between sections 974-20 and 974-30 of the ITAA 1997

Debt/Equity financing: unsecured notes that may be converted into preference shares

Characterisation of a 15 year convertible note

Revolving credit facility: Facility Agreement - debt interest

Division 974: application of the debt test to Certificates of Deposit

Income tax: can the assignment of an intra-group debt or income stream to an entity that is not a member of the consolidated group give rise to a debt interest for the head company of the group under Division 974 of the Income Tax Assessment Act 1997?

Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an 'effectively non-contingent obligation' to provide 'financial benefits' as interest payments from the time that a change in the interest rate could take effect?

Income tax: application of section 177EA of the Income Tax Assessment Act 1936 to non-share distributions on certain 'dollar value' convertible notes

Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997 , does an issuing company have an effectively non-contingent obligation to provide a financial benefit by way of periodic interest returns on an interest bearing convertible note from the time that it can be converted at the issuing company's option into ordinary shares in that company?

Are certain preference shares which give a right of security of tenure over a unit in a retirement village 'debt interests'?

Debt/Equity Borderline: the characterisation of a priority partnership interest issued by a corporate limited partnership