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42 documents
Consolidation: meaning of a day for purposes of Part 3-90 of the ITAA 1997
Consolidation: Membership and Discretionary Trusts
Consolidation: transfer testing - transferring losses to the head company of a MEC group after cessation of another MEC group
Consolidation: Public trading trust - choice to form a consolidated group
Consolidation: income and deductions - restructure of membership interests supporting components of life insurance business
Consolidation: tax consequences on exit - restructure of membership interests supporting components of life insurance business
Consolidation: MEC group - appointment of a replacement provisional head company - MEC group reduced to a single eligible tier-1 company
Consolidation: tax sharing agreement - the head company's due time for a group liability following an amendment to a nil assessment
Income tax: consolidation: can the head company of a consolidated group claim a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest paid on funds borrowed before consolidation and on-lent interest-free to a subsidiary member of the consolidated group?
Income tax: consolidation: does the continuing majority-owned entity test in subsections 701A-1(1) and 701A-1(2) of the Income Tax (Transitional Provisions) Act 1997 require tracing through interposed entities to the ultimate beneficial owners to determine whether there has been a change in the majority ownership of an entity during the period from 27 June 2002 until the entity becomes a subsidiary member of a consolidated group?
Income tax: consolidation: is there any apportionment under section 707-335 of the Income Tax Assessment Act 1997 to the limits calculated under subsection 707-350(3) of the Income Tax (Transitional Provisions) Act 1997 regarding the utilisation of losses?
Income tax: consolidation: is an adjustment under section 705-160 of the Income Tax Assessment Act 1997 required where the relevant membership interests are in a chosen transitional entity with losses?
Income tax: consolidation: will a choice to consolidate under Part 3-90 of the Income Tax Assessment Act 1997 affect the method of income recognition of the consolidated group?
Income tax: consolidation: can the transferee make a choice under subsection 707-327(4) of the Income Tax (Transitional Provisions) Act 1997 to treat part of a loss transferred, under Subdivision 707-A of the Income Tax Assessment Act 1997, from a value donor as being included in another bundle of losses?
Income tax: consolidation: can the transferee make more than one choice, under subsection 707-327(4) of the Income Tax (Transitional Provisions) Act 1997, to treat a value donor's loss as being included in another bundle of losses?
Income tax: consolidation: can the head company of a multiple entry consolidated group claim a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest paid on funds borrowed after formation of the MEC group from outside the group by it or a subsidiary member to buy shares in an existing eligible tier-1 company of the group?
Income tax: consolidation: can the head company of a consolidated group claim a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest paid on funds borrowed from outside the group, where the funds were borrowed either before or after formation of the consolidated group, by it or a subsidiary member to buy shares in an existing subsidiary member from another member of the consolidated group?
Income tax: consolidation: can the transfer of a tax loss under section 707-120 of the Income Tax Assessment Act 1997, to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, constitute a COT transfer?
Income tax: consolidation: can a tax loss, transferred under section 707-120 of the Income Tax Assessment Act 1997 to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, satisfy the condition described in paragraph 707-350(1)(c) of the Income Tax (Transitional Provisions) Act 1997?
Income tax: can a consolidated special purpose financial report of a head company of a tax consolidated group satisfy clause 1.1 of Schedule 2 to the Income Tax Assessment Regulations 1997 where transactions within the same category are translated using inconsistent methodologies?