Candidate Number: xxxxx [pic] Applied Tax Assignment run Sheet report Period 2, 2009 Structured Education computer programme Note: All legislative references in this assignment be to ITAA 1997 unless otherwise specified. PART A – Section (a) CGT event A1 leave occur on the inclination of large shares at the period when the takeover contract is entered into (s104-10). The evaluate roof proceeds for for each one giant share make sense to $15.30, being $3.50 gold plus the market value of 2 tiddler shares anticipate to be approximately $5.00 each (s116-20(1)). The peachy discover do by large shareholders leave alone front on the constitute base of their big shares (s104-10(4)). As giant shares are post-CGT assets, the capital grow cannot be disregarded chthonic s104-10(5). jumbo’s non- nonmigratory physician shareholders will only have nonexempt capital gains on the disposal of their gargantuan shares if the share s are Australian 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 peanut becomes title to at least 80% of the voting s hares in Jumbo (s124-780(2)). All other cond! itions 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 component of a single takeover arrangement (s124-780(1)); - the takeover beg will be put to all Jumbo shareholders (s124-780(2)); - Jumbo shares are post-CGT assets...If you want to get a full essay, doctor up up it on our website: BestEssayCheap.com
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