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Legislation
ATO documents that consider ITAA 1997 s 974-75(1)
54 documents
Classification of certain converting preference shares under Division 974 of the ITAA 1997
Debt/Equity: Redeemable Preference Share
Convertible Notes and the debt/equity borderline
Redeemable preference shares: debt interest under Division 974
Redeemable preference shares: interaction between sections 974-20 and 974-30 of the ITAA 1997
Interest free loan to private company repayable if shareholding is sold or the company is sold: application of the debt-equity interest provisions
Debt/Equity Interest: Redeemable Preference Shares - equity interest
Debt/Equity financing: unsecured notes that may be converted into preference shares
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: can a share in a company be a convertible interest by satisfying item 4 of the table in subsection 974-75(1) of the Income Tax Assessment Act 1997?
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