41-44 of 44 results
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. ...
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. ...
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. ...