R&D Tax Incentive – R&D proposed changes released – $150m threshold, offset at corporate rate plus 13.5% points, $4m cap, higher intensity

On 8 May 2018, the Government announced it will reform the Research and Development Tax Incentive (R&DTI) to better target the program and improve its integrity and fiscal affordability in response to the recommendations of the 2016 Review of the R&D Tax Incentive.  And on 29 June 2018, Treasury released its consultation material: A Consultation…

Newmont Canada FN Holdings ULC v FCT – Commissioner refused stay of proceedings pending outcome of Resource Capital Fund IV case – Div 855 ‘land rich’ decision

The Federal Court has refused to grant the Tax Office a stay of proceedings in a case involving Div 855 ITAA 1997, pending the outcome of an appeal in a different, but similar, issue. The taxpayer appealed under Pt IVC TAA against assessments for the 2011 income year totalling just over $120m (the Newmont appeals). The…