This paper focuses on practical corporate tax issues that advisers and management should consider when structuring and financing transactions, including:
- capital raising
- debt/equity
- hybrid instruments including Mills case (taxpayer allowed special leave to appeal to High Court on 10 October 2012)
- Corporations Act 2001 s 254T amendments
- repatriation of profits including franking of dividends and withholding taxes
- returns of capital/share buy-backs
- proposed business tax working group reforms.