TABL5518 Consolidations and Group Structures - 2018

TABL5518
Postgraduate
Semester 2
6 Units of Credit
On Campus
Taxation & Business Law
This course outline is for the current semester. To view outlines from other years and/or semesters, visit the archives

1. Course Details

Summary of Course

The study guide for Consolidations and Group Structures comprises five modules:

  • Module 1 Corporate tax planning: Case studies
  • Module 2 Consolidated groups
  • Module 3 Corporate reorganisations and specific anti-avoidance
  • Module 4 Non-consolidated groups
  • Module 5 Capital profits

Teaching Times and Locations

Please note that teaching times and locations are subject to change. Students are strongly advised to refer to the Class Timetable website for the most up-to-date teaching times and locations.

View course timetable

Course Policies & Support

Course Aims and Relationship to Other Courses

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 other entities
  • introduce students to ‘complex structures’ (i.e., structures consisting of multiple vehicles, corporate groups)
  • develop analytical skills, and both a practical and theoretical understanding of the principles governing the choice to consolidate a group.

Tax and other principles bearing upon companies, partnerships and trusts are considered in relative isolation in TABL5507 Taxation of Corporate Finance, and TABL5505 Taxation of Trusts. TABL5518 Consolidations and Group Structures is a third tier course designed to lead students into the complex interaction between the key vehicles when used in conjunction with one another.

2. Staff Contact Details

Position Title Name Email Location Phone Consultation Times
Lecturer-in-chargeMrSteven Koufomanolis
+61 2 406 874 418 By appointment

Communication with staff

When you contact staff by email, please:

  • Use your University (not personal) email address
  • Specify the course TABL5518 as appropriate; and
  • Sign off by using your name and student identity number.

3. Learning and Teaching Activities

Approach to Learning and Teaching in the Course

How to Use These Study Materials

If you are new to flexible learning you should carefully read this Course Outline. It contains most of the relevant information about how this course will be run and the expectations of you as a student. You should also refer to the Suggested Study Schedule as a guide to completing your coursework. So as to get the most out of your study we recommend that you follow this study schedule through the course and fit various time demands into a well-organised diary. Systematic study through the Semester is the key to success in a flexible learning program.

The Study Guide (which includes this Course Outline and the individual Modules and is sometimes referred to as the study materials or course materials) can help you in three ways.

  1. It sets out a clear path of study over the Semester and helps you plan your workload. It also identifies learning outcomes and key concepts at the start of each module and provides a series of activities to help you learn actively and manage your own progress through the course.
  2. It contains the core content for the course (often with reference to legislation, textbooks and other relevant material). The structure and layout of the Study Guide is designed to highlight key points and assist your revision for assignments, research papers and examinations.
  3. It tells you when to refer to textbooks, legislation and other readings, giving precise details of what you should read.

Features of the Study Guide

Each module includes a range of features to assist you in managing your learning and developing study skills. These features include:

  • Overview page
  • Heading levels
  • Learning outcomes and key concepts
  • Module text
  • Activities and feedback
  • Readings
  • Margin notes
  • Instructional icons

Tax Distance Course Student Guide

The Tax Distance Course Student Guide is a vital source of information for students studying flexible learning courses. It provides administrative and other information specific to studying these courses and you should make a point of being familiar with its contents. You can access the 2018 Tax Distance Student Guide from your Moodle course website(s).

Audio Conferences

Throughout this course, you will have the opportunity to attend live audio conferences (conducted by telephone). Instructions on preparing for and participating in audio conferences are available on the Taxation & Business Law website and in your course Moodle website.

These conferences provide an opportunity for you to clarify and extend your understanding of the material in this course. They are designed to try out new ideas and give you a forum to ask questions and discuss issues with your lecturer and other students. Do not be afraid to participate—it is only by trying out new ideas and exploring their dimensions that you will learn in any real depth.

Thorough preparation is essential if you are to gain maximum benefit from a Conference. You can only start to come to grips with material if you work on it actively. As a general rule, each Conference will cover the module/s between the previous Conference and the week it falls within on the Suggested Study Schedule. However, more specific information on material to be covered in each Conference may be provided via Moodle throughout the Semester. Exact dates and times for Conferences will be advised via a timetable that you will find on Moodle and on the TBL Website (under Timetables).

There are six audio conferences scheduled for this course during the Semester. Each audio conference is of approximately one and a half hours’ duration.

Remember audio conferences are not lectures—your active participation is an important part of the learning experience and preparation for examinations!

Learning Activities and Teaching Strategies

​Learning Activities in this course are undertaken through a combination of Audio Conferences, an individual or group research paper and a final written exam.  The benefit to students from this mixed learning approach is that they experience a multifaceted approach to the learning experience, some through instruction and interaction with the lecturer and others where the individual assumes responsibility.

As a result, the teaching strategy adopted is not only focused on learning the subject matter for the course but ensuring students learn to pace their learning experiences and manage their time efficiently and effectively as well as ensuring they engage with their lecturer through webinars and when issues arise through their studies.

5. Course Resources

​Prescribed text:

There are no prescribed textbooks for this course.

Act/s:

You must purchase or have access to the following publication/s:

Income Tax Assessment Act 1936

Income Tax Assessment Act 1997

Citation and Style Guide:

In presenting written work for assessment in this course you must use an appropriate and consistent style for referencing and citation. The following is a selection of acceptable citation and style guides, which you may use as the basis for your written work. You must purchase or have access to one of the following publications.

(This is free to download and is the citation style guide used by the majority of Australian legal journals.)

  • Rozenberg P, Australian guide to uniform legal citation (Sydney: Lawbook Co, 2nd ed, 2003).
  • Stuhmcke A, Legal referencing (Sydney: LexisNexis, 4th ed, 2012).

Recommended References:

Below is a list of further references that you may find useful in this course. Purchase of recommended references is not required.

  • Woodley M (ed), Osborn’s Concise Law Dictionary (London: Sweet & Maxwell, 12th ed, 2013).

This is the classic, concise dictionary of legal terms which is very useful for students of law based subjects.

Consolidation reference manual (Nat 6835)

Note the manual can be accessed by searching the ato.gov.au homepage using the term ‘Consolidation reference manual’. In addition, court cases on corporate taxation will provide a valuable source of learning about how judges have grappled with the difficult interpretational issues in this area. Further, journal articles by practitioners in the corporate tax field can provide an informative resource for understanding current patterns and trends around consolidations and group structures. Your electronic database access (explained further below) should provide you with the means to research and obtain relevant court cases, articles and other useful material.

Electronic Databases:

The UNSW library subscribes to several electronic databases.

The website for this course is on Moodle.

6. Course Evaluation & Development

​The School of Taxation & Business Law’s quality enhancement process involves regular review of its courses and study materials by content and educational specialists, combined with feedback from students. Towards the end of the semester, you will be asked to complete an online myExperience survey via Moodle to evaluate the effectiveness of your course lecturer and the actual course content. Your input into this quality enhancement process through the completion of these surveys is extremely valuable in assisting us in meeting the needs of our students and in providing an effective and enriching learning experience. The results of all surveys are carefully considered and do lead to action towards enhance the quality or course content and delivery.

7. Course Schedule

Week 1: 23 July
Activity

Reading

Topic

Module 1 Corporate tax planning: Case studies

Week 2: 30 July
Activity

Reading

Topic

Module 2 Consolidated groups

Week 3: 6 August
Activity

Reading/Audio Conference

Topic

Module 2 Consolidated groups

Assessment/Other

Audio Conference 1

Stream 1: Registration group topic

Week 4: 13 August
Activity

Reading/Audio/Synopsis

Topic

Module 2 Consolidated groups

Assessment/Other

Stream 2: Synopsis (if required)

Week 5: 20 August
Activity

Reading/Audio Conference

Topic

Module 3 Corporate reorganisation and specific anti-avoidance

Assessment/Other

Audio Conference 2

Week 6: 27 August
Activity

Reading/Research Plan

Topic

Module 3 Corporate reorganisation and specific anti-avoidance

Assessment/Other

Stream 2: Research Plan

Week 7: 3 September
Activity

Reading/Audio Conference

Topic

Module 3 Corporate reorganisation and specific anti-avoidance

Assessment/Other

Audio Conference 3

Stream 1: Draft research paper

Week 8: 10 September
Activity

Reading

Topic

Module 4 Non-consolidated groups

Week 9: 17 September
Activity

Reading/Audio Conference

Topic

Module 4 Non-consolidated groups

Assessment/Other

Audio Conference 4

Mid semester break: : 22 September - 1 October
Week 10: 2 October
Activity

Reading

Topic

Module 4 Non-consolidated groups

Week 11: 8 October
Activity

Reading/Audio Conference/Research paper

Topic

Module 5 Capital profits

Assessment/Other

Audio Conference 5

Stream 1: Final research paper

Stream 2: Research paper

 

Week 12: 15 October
Activity

Reading

Topic

Module 5 Capital profits

Week 13: 22 October
Topic

Revision

Assessment/Other

Audio Conference 6

Stream 1: Individual submission

8. Policies

Information about UNSW Business School protocols, University policies, student responsibilities and education quality and support.

Program Learning Outcomes

The Business School places knowledge and capabilities at the core of its curriculum via seven Program Learning Outcomes (PLOs). These PLOs are systematically embedded and developed across the duration of all coursework programs in the Business School.

PLOs embody the knowledge, skills and capabilities that are taught, practised and assessed within each Business School program. They articulate what you should know and be able to do upon successful completion of your degree.

Upon graduation, you should have a high level of specialised business knowledge and capacity for responsible business thinking, underpinned by ethical professional practice. You should be able to harness, manage and communicate business information effectively and work collaboratively with others. You should be an experienced problem-solver and critical thinker, with a global perspective, cultural competence and the potential for innovative leadership.

All UNSW programs and courses are designed to assess the attainment of program and/or course level learning outcomes, as required by the UNSW Assessment Design Procedure. It is important that you become familiar with the Business School PLOs, as they constitute the framework which informs and shapes the components and assessments of the courses within your program of study.

PLO 1: Business knowledge

Students will make informed and effective selection and application of knowledge in a discipline or profession, in the contexts of local and global business.

PLO 2: Problem solving

Students will define and address business problems, and propose effective evidence-based solutions, through the application of rigorous analysis and critical thinking.

PLO 3: Business communication

Students will harness, manage and communicate business information effectively using multiple forms of communication across different channels.

PLO 4: Teamwork

Students will interact and collaborate effectively with others to achieve a common business purpose or fulfil a common business project, and reflect critically on the process and the outcomes.

PLO 5: Responsible business practice

Students will develop and be committed to responsible business thinking and approaches, which are underpinned by ethical professional practice and sustainability considerations.

PLO 6: Global and cultural competence

Students will be aware of business systems in the wider world and actively committed to recognise and respect the cultural norms, beliefs and values of others, and will apply this knowledge to interact, communicate and work effectively in diverse environments.

PLO 7: Leadership development

Students will develop the capacity to take initiative, encourage forward thinking and bring about innovation, while effectively influencing others to achieve desired results.

These PLOs relate to undergraduate and postgraduate coursework programs.  Separate PLOs for honours and postgraduate research programs are included under 'Related Documents'.

Business School course outlines provide detailed information for students on how the course learning outcomes, learning activities, and assessment/s contribute to the development of Program Learning Outcomes.

RELATED DOCUMENTS


UNSW Graduate Capabilities

The Business School PLOs are linked to UNSW Graduate Capabilities, a set of generic abilities and skills that all students are expected to achieve by graduation. These capabilities articulate the University's institutional values, as well as future employer expectations.

UNSW Graduate Capabilities

The Business School PLOs also incorporate UNSW graduate capabilities, a set of generic abilities and skills that all students are expected to achieve by graduation. These capabilities articulate the University’s institutional values, as well as future employer expectations.

UNSW Graduate CapabilitiesBusiness School PLOs
Scholars capable of independent and collaborative enquiry, rigorous in their analysis, critique and reflection, and able to innovate by applying their knowledge and skills to the solution of novel as well as routine problems.
  • PLO 1: Business knowledge
  • PLO 2: Problem solving
  • PLO 3: Business communication
  • PLO 4: Teamwork
  • PLO 7: Leadership development

Entrepreneurial leaders capable of initiating and embracing innovation and change, as well as engaging and enabling others to contribute to change
  • PLO 1: Business knowledge
  • PLO 2: Problem solving
  • PLO 3: Business communication
  • PLO 4: Teamwork
  • PLO 6: Global and cultural competence
  • PLO 7: Leadership development

Professionals capable of ethical, self-directed practice and independent lifelong learning
  • PLO 1: Business knowledge
  • PLO 2: Problem solving
  • PLO 3: Business communication
  • PLO 5: Responsible business practice

Global citizens who are culturally adept and capable of respecting diversity and acting in a socially just and responsible way.
  • PLO 1: Business knowledge
  • PLO 2: Problem solving
  • PLO 3: Business communication
  • PLO 4: Teamwork
  • PLO 5: Responsible business practice
  • PLO 6: Global and cultural competence

While our programs are designed to provide coverage of all PLOs and graduate capabilities, they also provide you with a great deal of choice and flexibility.  The Business School strongly advises you to choose a range of courses that assist your development against the seven PLOs and four graduate capabilities, and to keep a record of your achievements as part of your portfolio. You can use a portfolio as evidence in employment applications as well as a reference for work or further study. For support with selecting your courses contact the UNSW Business School Student Centre.



Academic Integrity and Plagiarism

Academic Integrity is honest and responsible scholarship. This form of ethical scholarship is highly valued at UNSW. Terms like Academic Integrity, misconduct, referencing, conventions, plagiarism, academic practices, citations and evidence based learning are all considered basic concepts that successful university students understand. Learning how to communicate original ideas, refer sources, work independently, and report results accurately and honestly are skills that you will be able to carry beyond your studies.

The definition of academic misconduct is broad. It covers practices such as cheating, copying and using another person’s work without appropriate acknowledgement. Incidents of academic misconduct may have serious consequences for students.

Plagiarism

UNSW regards plagiarism as a form of academic misconduct. UNSW has very strict rules regarding plagiarism. Plagiarism at UNSW is using the words or ideas of others and passing them off as your own. All Schools in the Business School have a Student Ethics Officer who will investigate incidents of plagiarism and may result in a student’s name being placed on the Plagiarism and Student Misconduct Registers.

Below are examples of plagiarism including self-plagiarism:

Copying: Using the same or very similar words to the original text or idea without acknowledging the source or using quotation marks. This includes copying materials, ideas or concepts from a book, article, report or other written document, presentation, composition, artwork, design, drawing, circuitry, computer program or software, website, internet, other electronic resource, or another person's assignment, without appropriate acknowledgement of authorship.

Inappropriate Paraphrasing: Changing a few words and phrases while mostly retaining the original structure and/or progression of ideas of the original, and information without acknowledgement. This also applies in presentations where someone paraphrases another’s ideas or words without credit and to piecing together quotes and paraphrases into a new whole, without appropriate referencing.

Collusion: Presenting work as independent work when it has been produced in whole or part in collusion with other people. Collusion includes:

  • Students providing their work to another student before the due date, or for the purpose of them plagiarising at any time
  • Paying another person to perform an academic task and passing it off as your own
  • Stealing or acquiring another person’s academic work and copying it
  • Offering to complete another person’s work or seeking payment for completing academic work

Collusion should not be confused with academic collaboration (i.e., shared contribution towards a group task).

Inappropriate Citation: Citing sources which have not been read, without acknowledging the 'secondary' source from which knowledge of them has been obtained.

Self-Plagiarism: ‘Self-plagiarism’ occurs where an author republishes their own previously written work and presents it as new findings without referencing the earlier work, either in its entirety or partially. Self-plagiarism is also referred to as 'recycling', 'duplication', or 'multiple submissions of research findings' without disclosure. In the student context, self-plagiarism includes re-using parts of, or all of, a body of work that has already been submitted for assessment without proper citation.

To see if you understand plagiarism, do this short quiz:https://student.unsw.edu.au/plagiarism-quiz

Cheating

The University also regards cheating as a form of academic misconduct. Cheating is knowingly submitting the work of others as their own and includes contract cheating (work produced by an external agent or third party that is submitted under the pretences of being a student’s original piece of work). Cheating is not acceptable at UNSW.

If you need to revise or clarify any terms associated with academic integrity you should explore the 'Working with Academic Integrity' self-paced lessons available at: https://student.unsw.edu.au/aim.

For UNSW policies, penalties, and information to help you avoid plagiarism see: https://student.unsw.edu.au/plagiarism as well as the guidelines in the online ELISE tutorials for all new UNSW students: http://subjectguides.library.unsw.edu.au/elise. For information on student conduct see:https://student.unsw.edu.au/conduct.

For information on how to acknowledge your sources and reference correctly, see: https://student.unsw.edu.au/referencing. If you are unsure what referencing style to use in this course, you should ask the lecturer in charge.

Student Responsibilities and Conduct

Students are expected to be familiar with and adhere to university policies in relation to class attendance and general conduct and behaviour, including maintaining a safe, respectful environment; and to understand their obligations in relation to workload, assessment and keeping informed.

Information and policies on these topics can be found on the'Managing your Program' website.

Workload

It is expected that you will spend at least nine to ten hours per week studying for a course except for Summer Term courses which have a minimum weekly workload of eighteen to twenty hours. This time should be made up of reading, research, working on exercises and problems, online activities and attending classes. In periods where you need to complete assignments or prepare for examinations, the workload may be greater. Over-commitment has been a cause of failure for many students. You should take the required workload into account when planning how to balance study with employment and other activities.

We strongly encourage you to connect with your Moodle course websites in the first week of semester. Local and international research indicates that students who engage early and often with their course website are more likely to pass their course.

View more information on expected workload

Attendance

Your regular and punctual attendance at lectures and seminars or in online learning activities is expected in this course. The Business School reserves the right to refuse final assessment to those students who attend less than 80% of scheduled classes where attendance and participation is required as part of the learning process (e.g., tutorials, flipped classroom sessions, seminars, labs, etc.).

View more information on attendance

General Conduct and Behaviour

You are expected to conduct yourself with consideration and respect for the needs of your fellow students and teaching staff. Conduct which unduly disrupts or interferes with a class, such as ringing or talking on mobile phones, is not acceptable and students may be asked to leave the class.

View more information on student conduct

Health and Safety

UNSW Policy requires each person to work safely and responsibly, in order to avoid personal injury and to protect the safety of others.

View more information on Health and Safety

Keeping Informed

You should take note of all announcements made in lectures, tutorials or on the course web site. From time to time, the University will send important announcements to your university e-mail address without providing you with a paper copy. You will be deemed to have received this information. It is also your responsibility to keep the University informed of all changes to your contact details.


Special Consideration

You must submit all assignments and attend all examinations scheduled for your course. You can apply for special consideration when illness or other circumstances beyond your control, interfere with your performance in a specific assessment task or tasks. Special Consideration is primarily intended to provide you with an extra opportunity to demonstrate the level of performance of which you are capable.

General information on special consideration for undergraduate and postgraduate courses can be found in the Assessment Implementation Procedure and the Current Students page.

Please note the following:

  1. Applications will not be accepted by teaching staff. The lecturer-in-charge will be automatically notified when you lodge an online application for special consideration
  2. Decisions and recommendations are only made by lecturers-in-charge (or by the Faculty Panel in the case of final exam special considerations), not by tutors
  3. Applying for special consideration does not automatically mean that you will be granted a supplementary exam or other concession
  4. Special consideration requests do not allow lecturers-in-charge to award students additional marks

Business School Protocol on requests for Special Consideration

The lecturer-in-charge will need to be satisfied on each of the following before supporting a request for special consideration:

  1. Does the medical certificate contain all relevant information? For a medical certificate to be accepted, the degree of illness and its impact on the student must be stated by the medical practitioner (severe, moderate, mild). A certificate without this will not be valid. Students should also note that only medical certificates issued after physically visiting a registered medical practitioner will be accepted. Medical certificates submitted for Special Consideration should always be requested from a registered medical practitioner that you have seen at a medical practice. Certificates obtained online or via social media may be fraudulent and if relied upon could result in a breach of the UNSW Student Code.
  2. Has the student performed satisfactorily in the other assessment items? To understand what Satisfactory Performance means in this course, please refer to the 'Formal Requirements' section in Part A of your Course Outline

Special Consideration and the Final Exam in undergraduate and postgraduate courses

Applications for special consideration in relation to the final exam are considered by a Business School Faculty panel to which lecturers-in-charge provide their recommendations for each request. If the Faculty panel grants a special consideration request, this will entitle the student to sit a supplementary examination. No other form of consideration will be granted. The following procedures will apply:

  1. Supplementary exams will be scheduled centrally and will be held approximately two weeks after the formal examination period. Supplementary exams for Semester 1, 2018 will be held during the period 14 - 21 July, 2018. Supplementary exams for Semester 2, 2018 will be held during the period 8 - 15 December, 2018. Students wishing to sit a supplementary exam will need to be available during this period.
    If a student lodges a special consideration application for the final exam, they are stating they will be available on this date. Supplementary exams will not be held at any other time.

  2. Where a student is granted a supplementary examination as a result of a request for special consideration, the student’s original exam (if completed) will be ignored and only the mark achieved in the supplementary examination will count towards the final grade. Absence from a supplementary exam without prior notification does not entitle the student to have the original exam paper marked, and may result in a zero mark for the final exam.

The Supplementary Exam Protocol for Business School students is available at: http://www.business.unsw.edu.au/suppexamprotocol

For special consideration for assessments other than the final exam refer to the ‘Assessment Section’ in your course outline.


Protocol for Viewing Final Exam Scripts

The UNSW Business School has set a protocol under which students may view their final exam script. Please check the protocol here.

Given individual schools within the Faculty may set up a local process for viewing final exam scripts, it is important that you check with your School whether they have any additional information on this process. Please note that this information might also be included in your course outline.

Student Support and Resources

The University and the Business School provide a wide range of support services and resources for students, including:

Business School Education Quality and support Unit (EQS)
The EQS offers academic writing, study skills and maths support specifically for Business students. Services include workshops, online resources, and individual consultations.
Level 1, Room 1033, Quadrangle Building.
bschoolconsults@unsw.edu.au
02 9385 7577 or 02 9385 4508

Business School Student Centre
The Business School Student Centre provides advice and direction on all aspects of admission, enrolment and graduation.
Level 1, Room 1028 in the Quadrangle Building
02 9385 3189

UNSW Learning Centre
The UNSW Learning Centre provides academic skills support services, including workshops and resources, for all UNSW students. See their website for details.
Lower Ground Floor, North Wing Chancellery Building.
learningcentre@unsw.edu.au
02 9385 2060

Educational Support Service
Educational Support Advisors work with all students to promote the development of skills needed to succeed at university, whilst also providing personal support throughout the process. Check their website to request an appointment or to register in the Academic Success Program.
John Goodsell Building, Ground Floor.
advisors@unsw.edu.au
02 9385 4734

Library services and facilities for students
The UNSW Library offers a range of collections, services and facilities both on-campus and online.
Main Library, F21.
02 9385 2650

Moodle eLearning Support
Moodle is the University’s learning management system. You should ensure that you log into Moodle regularly.
externalteltsupport@unsw.edu.au
02 9385 3331

UNSW IT
UNSW IT provides support and services for students such as password access, email services, wireless services and technical support.
UNSW Library Annexe (Ground floor).
itservicecentre@unsw.edu.au
02 9385 1333

Disability Support Services
UNSW Disability Support Services provides assistance to students who are trying to manage the demands of university as well as a health condition, learning disability or who have personal circumstances that are having an impact on their studies. Disability Advisers can arrange to put in place services and educational adjustments to make things more manageable so that students are able to complete their course requirements. To receive educational adjustments for disability support, students must first register with Disability Services.
Ground Floor, John Goodsell Building.
disabilities@unsw.edu.au
02 9385 4734

UNSW Counselling and Psychological Services
Provides support and services if you need help with your personal life, getting your academic life back on track or just want to know how to stay safe, including free, confidential counselling.
Level 2, East Wing, Quadrangle Building.
counselling@unsw.edu.au
02 9385 5418

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