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28 documents
Income tax: consolidation: membership: are the eligible tier-1 companies of a foreign-owned group required to form a single MEC group which includes all those eligible tier-1 companies?
Income tax: consolidation: membership: can an Australian resident company qualify as an eligible tier-1 company of a MEC group if a foreign resident entity is interposed between the Australian resident company and the top company of the group?
Income tax: consolidation: membership: if an Australian resident entity satisfies all the conditions for being a member of a consolidatable or potential MEC group including, where appropriate, either section 701C-10 or section 701C-15 of the Income Tax (Transitional Provisions) Act 1997, can that entity remain outside the group when the group consolidates?
Income tax: consolidation: membership: when does a MEC group come into existence where a valid choice to form a MEC group is made under section 719-50 of the Income Tax Assessment Act 1997 ?
Income tax: consolidation: can the profit received on the disposal of membership interests in a subsidiary member of a consolidated group be income according to ordinary concepts?
Income tax: consolidation: membership: where a consolidatable group comes into existence at some time during a day can the head company make a choice under section 703-50 of the Income Tax Assessment Act 1997 specifying that day as the day on and after which the consolidatable group is taken to be consolidated?
Income tax: consolidation: if a member of a consolidated group is reinstated under section 601AH of the Corporations Act 2001 after having been deregistered, will it be taken to have continued to satisfy the membership requirements in section 703-15 of the Income Tax Assessment Act 1997 during the period between deregistration and reinstatement?
Income tax: consolidation: does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 apply in determining whether distributions by the liquidator of a head company represent 'income derived' by the head company for the purposes of section 47 of the Income Tax Assessment Act 1936?