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Legislation
ATO documents that consider ITAA 1997 s 974-20(1)(d)
8 documents
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: Warwick Credit Union Ltd - Capital Notes
Debt/Equity: Redeemable Preference Share
Debt/Equity Borderline: characterisation of related schemes
Debt/Equity Interest: Redeemable Preference Shares - equity interest
Characterisation of a 15 year convertible note
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: 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?