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An update on capital management issues including debt/equity: recent developments paper


The management of capital and optimisation of capital structures remains a key focus for companies. This paper explores recent developments surrounding the taxation treatment of various capital management initiatives, including:

  • the decision in Mills and the implications for franked instruments
  • the implications of the decision in Consolidated Media Holdings
  • emerging issues under the debt/equity rules
  • the status of the share buyback reforms.

Author profiles

Simon Jenner CTA
Simon is a Partner in the Financial Services Tax practice at EY, specialising in banking and capital markets. Simon has over 24 years’ experience advising large corporates on a variety of tax issues, including capital management, capital raisings, mergers, acquisitions, disposals and the application of the tax consolidation regime. He has also advised extensively on the application of the taxation of financial arrangements rules. - Current at 11 February 2021
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Steven Guo
Steven Guo is a Senior Associate in the Sydney office of Greenwoods & Herbert Smith Freehills. He joined the firm in 2016, having previously worked in an international accounting firm since 2012. Steven provides a wide range of tax advisory and tax compliance services to clients mainly in the real estate and funds management industry. Steven holds a Bachelor of Commerce and Bachelor of Laws (Honours) from the University of NSW. He is a member of Chartered Accountants Australia and New Zealand and admitted as a solicitor in NSW. - Current at 14 July 2017
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This was presented at NSW 6th Annual Tax Forum .

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Individual sessions

The evolving compliance obligation

Author(s):  Judy MORRIS,  David DRUMMOND

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Alternative dispute resolution

Author(s):  Deborah HASTINGS,  Gina LAZANAS,  Judy SULLIVAN

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Franking dividends - Some tips and traps

Author(s):  Brent MURPHY

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Financial services reforms and regulations

Author(s):  Nidal DANOUN

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The promoter penalties regime

Author(s):  Aislinn WALWYN,  George MONTANEZ

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