Australia recently introduced a revolutionary new consolidation regime for taxing wholly-owned groups of resident entities. Under consolidation, the "head company" of a wholly-owned group may elect to have the group treated as a single entity for tax purposes. The new regime has far-reaching tax and commercial consequences not only for the members of corporate groups but also for persons who subsequently acquire interests in such entities. One of the core rules of the consolidation regime is the "joint and several liability rule", which has significant practical ramifications for persons who contemplate purchasing interests in Australian entities that are members of a "consolidated" or "consolidatable" group. After explaining the legislative background and policy intent and briefly describing the new regime, the article discusses its core rules and examines some of the challenging issues that arise under the joint and several liability rule.