31-40 of 135 results
Allens advises Bendigo and Adelaide Bank on offer of Capital Notes
The Capital Notes offer includes an Institutional Offer, a Broker Firm Offer, a Reinvestment Offer for the CPS2 shareholders and a Securityholder Offer. The transaction will support the Bank's ...
Full Federal Court dismisses Commissioner's transfer pricing appeal against Glencore
On 6 November 2020, the Full Court of the Federal Court of Australia handed down its much anticipated decision dismissing the Commissioner's appeal (save for one issue) against Glencore Investment Pty Ltd in a significant transfer pricing dispute. ...
Build-to-rent: stimulating recovery, ensuring resilience
Build-to-Rent (BTR) helps drive economic productivity, and with the right government intervention, could not only play a key role in Australia’s economic recovery from COVID-19, but also ensure the future liveability and resilience of our cities. ...
Double-duty provisions to receive much needed guidance on what constitutes 'land development'
The Victorian SRO has released a draft revenue ruling in an effort to provide practical guidance as to what types of activities constitute 'land development'. Unfortunately, the Draft Ruling does not overcome the existing uncertainty in some common situations and arguably seeks to expand the types of activities that may be considered 'land development'. ...
Mandatory binding arbitration of tax disputes
The approval of multilateral instruments in recent years means that binding arbitration of tax disputes is now available under the Tax Treaties with ten additional countries, including major trading partners Singapore, the United Kingdom, Japan and New Zealand. This trend is expected to continue. ...
Allens advises on Australia's largest super fund merger
Following the merger on 30 June 2020, FSS Trustee Corporation now manages over $125 billion on behalf of more than 1.1 million members from similar industries, such as education, healthcare and the ...
Buyers and sellers beware! Expenditure deductions denied and gains taxed as income
Recent decisions handed down by both the High Court and Federal Court in relation to the 'income/capital distinction' and 'blackhole expenditure' have produced a mix of predictable and unexpected, but generally unfavourable, outcomes for taxpayers. Most buyers have been denied deductions for the pur ...
Trusts and partnership: When is a confirmation of rights a declaration of trust?
The High Court of Australia held that certain deeds purporting to confirm a pre-existing trust of partnership property amounted to a new 'declaration of trust' within the meaning of the Western Australian stamp duty legislation. ...
Allens advises on Hills M2 Motorway $815m refinancing
Allens advised a lender sydicate of 20+ financiers on the $815m refinancing of the Hills M2 Motorway. The Hills M2 owned by Transurban is a 21km road linking Sydney's lower north shore and north west. ...
The Demerger Journey - from Facilitation to Frustration
The Demerger Journey - from Facilitation to Frustration. Partner Joe Power and Senior Associate Jay Prasad published their paper on the demerger tax rules at the inaugural Tax Institute Tax Summit at the International Convention Centre in Sydney in March 2020. The paper considers the correctness of the ATO’s recent views on the scope of the demerger tax relief provisions, and compares those provisions to analogous provisions in the UK, US and Canada. ...