Do you have questions related to relevant and topical matters and don't know where to find the answers? We have the answers for you! We are very excited to launch our new Q&A based webinar (series). The webinar (series) will focus
on practical issues experienced and problems and difficulties arising in practice. What makes this webinar (series) different?
The webinar will include pre-loaded videos covering the technical principles related to the topic which delegates can view at their own convenience
Delegates have the opportunity to submit questions that they have of practical issues and problems and these will be addressed in the live Q&A event
Delegates will obtain 3 hours verifiable CPD for each session aftersuccessful completion of assessment
Businesses have the opportunity to transact with each other and transfer assets in a tax neutral manner. In this session we will discuss strategies related to company formations and restructuring in order to minimise the resultant tax consequences for all parties involved. We will be answering your questions related to the practical difficulties experienced and best practice to follow in company formations and restructuring transactions.
During the course of August to November 2020, three senior tax professionals from Bowmans Gilfillan will anchor four interactive webinar sessions on the practical application of tax law relating to debt restructuring and corporate reorgan
isations. The sessions will also include an interactive debate on key themes emanating from conducting tax due diligences. They will share past experiences and knowledge, invite commercial specialists and will consider the tax and commercial impact of Covid-19, particularly as it relates to distressed companies. The webinar series aims to provide participants with a sense of the typical commercial drivers and the tax principles that play a role in these topics.
Delegates will have the opportunity to submit questions which will be addressed during the live Q&A section at the end of each session.
Delegates will earn two hours verifiable CPD for each session.
2. Corporate Reorganisations (21 September)
The session will introduce you to the Corporate Reorganisation tax rules.
The corporate tax rollover relief provisions enable the tax neutral transfer of assets to companies and defer the potential tax liability. A transaction needs to have certain characteristics for the relief to apply. Over the course of two sessions, the presenters will explore the nuances of each type of transaction that qualify for tax rollover relief. In the first session, the following transactions will be discussed in detail:
The acquisition by a company of assets in return for the issue of shares (“asset-for-share transactions”).
Transactions within the same South African group of companies (“intra-group transactions”).
Commercial themes, particular to each type of transaction, will be blended with the tax technical analysis.
This series of videos explores the tax aspects of company formations, considering the various tax provisions that should be considered. The series consists of 6 videos:
Outlines some of the the general tax aspects when setting up a
company and when selling a going concern to a company as well as an overview of the corporate rules set out in Part III of the Income Tax Act.
Setting up a company: aspects of shareholder financing.
Selling a going concern to a company: general tax issues.
Asset for share transactions: explains the general tax rules that will apply in the absence of the corporate rules, including section 40CA; and then the application and effect of the section 42 rollover relief.
This video explains the effect of applying the section 42 Roll-over relief, with an illustrative example.
Further explores the effects of applying section 42, considering what happens when the assets are sold for a combination of shares and cash, as well as the clawback provisions in section 42.
Looks at other considerations, in this case, the tax adjustments that must be made under section 24BA when there is a value mismatch.
Other issues to consider, in this case the deductibility of interest on a loan raised to fund the acquisition of shares, and the circumstances in which section 24O might apply.
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