Melbourne Law School The Melbourne Law Masters

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Subjects 2009


Corporate Taxation B (Companies and Consolidation) 730608

Prerequisite

Successful completion of Corporate Taxation A (Shareholders, Debt and Equity) or significant tax professional experience. Corporate Taxation A (Shareholders, Debt and Equity) has a focus on corporate tax issues at the shareholder level.

 

Objectives

A student who has successfully completed this subject should:

  • Have an understanding of the detailed rules and current practical problems involved in the taxation of companies at the company level, with most emphasis on company losses
  • Have a detailed knowledge and understanding of the rules for the taxation of consolidated corporate groups
  • Understand the policy and issues underlying taxation of corporate groups.
Syllabus

This is an advanced subject consisting of a detailed examination of the tax rules applied to companies with a focus on company losses and the taxation of consolidated corporate groups in a domestic setting in Australia. Principal topics will include:

  • Part 3-90 of the Income Tax Assessment Act 1997 (Cth) on taxation of consolidated corporate groups, including:
    • Tax cost setting on entry and exit from a group Single entity rule
    • Losses
    • Tax sharing agreements
  • Treatment of company losses and loss integrity rules for companies and consolidated groups in Divisions 165 and 166 of the Income Tax Assessment Act 1997 (Cth)
  • Other tax rules relating to companies, including imputation and corporate rollovers focusing on their interaction with the consolidated group and company loss regimes.
Prize

The BJ Shaw Law Prize is awarded to the student ranked first in this subject.