Subjects 2009
Corporate Taxation A (Shareholders, Debt and Equity) 730629
- Credited Courses: Graduate Diploma in Corporations and Securities Law 538; Graduate Diploma in Tax 187; Graduate Diploma in Transnational Law 333; Master of Commercial Law 504; Master of Laws (LLM) 502; Master of Tax 742
Objectives
A student who has successfully completed this subject should:
- Have an understanding of the policies, detailed rules and current practical problems involved in the taxation of companies and shareholders, particularly at the shareholder level
- Have an advanced understanding of the policies underlying Australia’s imputation system, shares, corporate distributions, debt-equity integrity rules and corporate rollovers.
Syllabus
This subject consists of a detailed examination of the tax rules applied to companies and shareholders in a domestic setting in Australia, with a focus on issues at the shareholder level. Students may also (but are not obliged to) complete Corporate Taxation B (Companies and Consolidation), which is an advanced subject with a detailed focus on corporate tax losses and taxation of consolidated groups.
Principal topics will include:
- The policy and problems of taxing companies and shareholders
- The corporate-shareholder imputation system
- Taxation treatment of contributions of share capital and assets to a company
- Share value shifting
- Taxation of company distributions and dealings with interests in companies, including liquidations and share buybacks
- Private company deemed dividends
- Franking credit and capital streaming and associated anti-avoidance rules
- Debt-equity classification
- Corporate rollovers.
