Candidate Number: xxxxx [pic] Applied Tax Assignment spawn Sheet report Period 2, 2009 Structured Education class Note: All legislative references in this assignment be to ITAA 1997 unless otherwise specified. PART A – Section (a) CGT event A1 ordain occur on the inclination of large shares at the sentence when the takeover contract is entered into (s104-10). The evaluate roof proceeds for distributively giant share make sense to $15.30, being $3.50 funds plus the market value of 2 tiddler shares anticipate to be approximately $5.00 each (s116-20(1)). The uppercase discover make by large shareholders depart front on the speak to base of their big shares (s104-10(4)). As gargantuan shares are post-CGT assets, the capital establish cannot be disregarded chthonic s104-10(5). jumbo’s non- resident physician shareholders will only have taxable capital gains on the disposal of their big shares if the shares are Austr alian taxable property i.e. if: - Jumbo directly or indirectly holds Australian real property which accounts for at least 50% of its total assets; and - the non-resident holds at least 10% interest in Jumbo. As no single shareholder holds more than 9% of Jumbo, the non-residents’ Jumbo shareholdings are not Australian taxable property.
Therefore, they will not have any taxable capital gain on the disposal of their Jumbo shares. Jumbo’s resident shareholders can elect to use the scrip for scrip roll-over in subdiv 124-M if underage becomes dignify to at least 80% of the voting shares in Jumbo (s124-780(2)). All other conditions! for roll-over under s124-780 are satisfied because: - Jumbo shareholders are exchanging their Jumbo shares for Minor shares (s124-780(1)); - shares in both Minor and Jumbo are ordinary shares (s124-780(1)); - the exchange occurs as fate of a single takeover arrangement (s124-780(1)); - the takeover complot will be put to all Jumbo shareholders (s124-780(2)); - Jumbo shares are post-CGT assets...If you want to get a full essay, batten up it on our website: BestEssayCheap.com
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