The Full Federal Court has allowed the Commissioner’s appeal against the decision of Pagone J in Resource Capital Fund IV LP v FCT [2018] FCA 41. The Federal Court had allowed an appeal by 2 US private equity limited partnerships in relation to the proper tax treatment of substantial profits made on the sale their shares…
Overview: I made the following submission to the Independent Review of the Tax Practitioners Board (TPB) and of the Act it regulates: the Tax Agents Services Act 2009 (headed by Mr Keith James). It submits that the ‘public interest’, in having suitable consumer protection, in all aspects of tax practice, will be best served…
T a x T e c h n i c a l – M o n t h l y N e w s – May 2019 Developments – This is a collection of developments in Australian tax law and practice that occurred in May 2019, which aims to be relevant to tax practitioners.[i] Compiled By F John…
Key News Summary – APRA announced its 2019 regulatory focus on superannuation, in the wake ‘banking’ Royal Commission and other developments, which included 8 matters, one of which was a review of the ‘sole purpose’ test, with a view to updating it and making it more specific. [Tax Month – Jan-April 2019]
Key News Summary – Australia and Israel have signed their first ‘Double Tax Agreement’ (DTA) which includes OECD/G20 base erosion and profit shifting (BEPS) recommendations. It will come into effect after being ratified in both countries. [Tax Month – Jan-April 2019]
The AAT has affirmed that most of the ATO’s objection decision as the taxpayer could not prove that the monies received were characterised as loans. The taxpayer was a Chinese businesswoman who has been living in Australia since 2006. She received large payments from China in the 2011, 2012 and 2013 years of income. [Tax…