|Year of offer||2019|
|Subject level||Graduate coursework Level 7|
|Fees||Subject EFTSL, Level, Discipline & Census Date|
This core tax subject examines the policies, detailed rules and current practical problems involved in the taxation of companies and shareholders in Australia, particularly at shareholder level. The lecturers are leading practitioners and they will consider the tax rules that apply to shares, corporate distributions, Australia‘s imputation system, the debt-equity integrity rules and the hybrid entity rules.
This subject consists of a detailed examination of the tax rules applied to companies and shareholders in a domestic setting in Australia, with a focus on issues at the shareholder level.
Principal topics include:
- The policy and problems of taxing companies and shareholders
- Tax treatment of contributions of share capital and assets to a company
- Debt-equity classification
- The corporate shareholder imputation system
- Private company deemed dividends
- Franking credit and capital streaming and associated anti-avoidance rules
- Taxation of company distributions and dealings with interests in companies, including liquidations and share buybacks
- Hybrid rules.
Intended learning outcomes
Participating in and successfully completing this subject will, through that participation, assist students in developing:
- Thorough and sophisticated understandings of:
- The policies, detailed rules and current practical problems involved in the taxation of companies and shareholders, particularly at shareholder level
- The imputation system, shares and corporate distributions
- The debt-equity integrity rules
- The skills to be able to:
- Research, examine, analyse, interpret and assess the effectiveness of these legal rules independently and critically
- Generate critical and creative ideas relating to taxation of companies and their shareholders
- Articulate and convey complex information regarding taxation of companies and their shareholders clearly
- Become an engaged participant in debate regarding the policies underlying Australia’s corporate and shareholder taxation system
- Become an autonomous practitioner and learner in the field of corporate tax with expert judgment.