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Legislation
ATO documents that consider ITAA 1997 s 974
138 documents
Debt and Equity Financing: obligation to withhold tax on a return on a debt interest under Division 974
Debt and Equity Financing: liability to withholding tax on a return on a debt interest under Division 974
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 Borderline: characterisation of related schemes
Debt/Equity Interest: Redeemable Preference Shares - equity interest
Capital gains tax: scrip for scrip rollover - redeemable preference shares exchanged for ordinary shares
Debt/Equity: whether redeemable preference shares are an equity interest or a debt interest
Debt/Equity: whether converting preference shares are an equity interest or a debt interest
Debt/Equity financing: unsecured notes that may be converted into preference shares
Debt deduction: interest paid on convertible notes
Characterisation of a 15 year convertible note
Commercial debt forgiveness: commercial debt - non-share equity interest
Debt/Equity: related scheme
Distribution statements for non-share equity interests
Debt/Equity: application of Division 974 to material changes made to a loan agreement
Debt/Equity: the timing of the deductibility of returns on a non equity share
Performance period for a stapled instrument under Division 974 of the ITAA 1997
Revolving credit facility: Facility Agreement - debt interest
Division 974: application of the debt test to Certificates of Deposit
Calculating the annually compounded internal rate of return referred to within subsection 25-85(5) for the purposes of subsection 25-85(3) of the Income Tax Assessment Act 1997.