To date, the focus of our tax system has been on transactions involving assets, with only limited attention being given to liabilities. Recent legislative developments are addressing this imbalance, albeit in a piecemeal fashion. This presentation deals with:
- ambiguities raised by the way in which the tax system has traditionally dealt with liabilities
- how liabilities alter tax outcomes on asset and entity acquisition transactions
- the proposed TOFA treatment of liabilities
- options for a more consistent tax treatment of liabilities.