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Consolidations and Group Structures - ATAX0418
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Faculty: Australian School of Business
 
 
School:  Aus School of Tax and Bus Law
 
 
Course Outline: See below
 
 
Campus: ATAX Campus
 
 
Career: Postgraduate
 
 
Units of Credit: 6
 
 
EFTSL: 0.12500 (more info)
 
 
Indicative Contact Hours per Week: 0
 
 
Enrolment Requirements:
 
 
Restricted to students enrolled in Programs 9250 or 9260, 9255, 9200, 9210, 9230 or 5740 or 9257 or 9231 or 5231
 
 
Excluded: ATAX0318, ATAX0518
 
 
CSS Contribution Charge:Band 3 (more info)
 
 
Tuition Fee:See Tuition Fee Schedule
 
 
Further Information: See Class Timetable
 
 

Description

This course deals with taxation of structures consisting of multiple 'vehicles'. It covers companies, partnerships and trusts operating in conjunction with one another and large corporate groups. This includes group consolidation. The course is designed to take you beyond a static consideration of the taxation of companies, partnerships and trusts in isolation, to a consideration of the 'synergies', the opportunities, the complexities, the problems, arising from their interaction. It pays particular attention to the operation of legal formalism and the general anti-avoidance provisions in Part IVA on these structures. It looks at intra-group and extra-group transactions. It looks at the new consolidation regime and other proposals for changes.


Recommended Prior Knowledge

ATAX0403 Taxation of Corporations
ATAX0411 Taxation of Capital Gains

Students without this prior knowledge may find that they need to take steps to ensure adequate understanding of the related area. Note: as some area of tax law are interrelated in some courses, we recommend that students either have prior knowledge of the related area or study another course in that area concurrently.

Course Objectives

This course aims to:
  • Provide an understanding of tax consolidation within groups in terms of what the rules are and what their purpose is
  • Offer a tax-orientated treatment of partnerships and joint ventures
  • Introduce students to 'complex structures' (ie, structures consisting of multiple vehicles, corporate groups)
  • Develop analytical skills, and both a practical and theoretical understanding of the principles governing the choice and structures of entities to be used for the purpose of trade or investment.

Main Topics

  • Corporate tax planning: Case studies
  • Anti-avoidance (inc legal formalism)
  • Consolidated groups (inc losses & reconstruction)
  • Non-consolidated groups
  • Capital profits

Assessment

1 Research Paper
1 Exam

Course Texts

Prescribed
Information regarding the Atax Textbook Lists for Semester 1 will be available on the UNSW Bookshop website from 1 February.

Information regarding the Atax Textbook Lists for Semester 2 will be available on the UNSW Bookshop website from 1 July.

Recommended
Refer to Course Profile supplied by Lecturer.

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© The University of New South Wales (CRICOS Provider No.: 00098G), 2004-2011. The information contained in this Handbook is indicative only. While every effort is made to keep this information up-to-date, the University reserves the right to discontinue or vary arrangements, programs and courses at any time without notice and at its discretion. While the University will try to avoid or minimise any inconvenience, changes may also be made to programs, courses and staff after enrolment. The University may also set limits on the number of students in a course.