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Recouping tax losses under Division 166 paper

Published on 27 May 09 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • the role of Division 166
  • the companies to whom Division 166 applies
  • how Division 166 modifies the basic continuity of ownership test
  • corporate change
  • the tracing concessions
  • the stakeholder thresholds of the concessional tracing rules
  • the no detriment rule: section 166-275
  • interposition of a new entity between notional shareholders.

Author profiles

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 12 May 2021
Click here to expand/collapse more articles by Martin FRY.
Jeannelle Menezes
Jeanelle works for Allens Arthur Robinson. - Current at 05 May 2009
Click here to expand/collapse more articles by Jeanelle MENEZES.

 

This was presented at Everything There is to Know About Company Losses and Tax .

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