John Morgan is a tax specialist lawyer of more than three decades experience now practicing at the Victorian Bar - w: www.FJMtax.com e: f.john.morgan@vicbar.com.au

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…

GSTR 2006/6 – meaning of ‘no improvements on the land’ – draft changes to the ‘Explanation’ section (relevant for GST-free Government grants and the ‘margin scheme’

On Wed 27.6.2018, the Commissioner released a draft of a further Explanation section in his GST Ruling GSTR 2006/6. This ruling considers the meaning of the phrase “improvements on the land” for GST purposes. The draft seeks to provide further details and clarification of the ATO view in order to make it easier for relevant entities…

Professional firms income allocation (income splitting) – no real pre-30 June 2018 replacement guidance from the ATO

On 25 June 2018, the Commissioner updated his website page on his suspended ‘guidelines’ for income allocation for professional firms (which is really about how much income principals in professional firms can ‘split’ with family members, without attracting audit attention from the Commissioner). He suspended his previous guidelines on 14 December 2017, citing various alleged…

GST withholding on purchase of certain ‘new’ residential premises and ‘potential residential land’ – Commissioner releases relevant online forms and instructions

From 1 July 2018, purchasers of new residential premises or potential residential land are required to withhold an amount of the contract price and pay this directly to the ATO as part of the settlement process. The ATO has released instructions on how to complete the new GST property settlement forms. Purchasers of new residential premises or…

TR 2018/4 – Effective life of depreciating assets from 1 July 2018 – Commissioner’s determination under s40-100

On 27 June 2018, the Commissioner issued TR 2018/4, setting out his determination of the effective life of depreciating assets, for the purposes of depreciation deductions under Division 40 of the ITAA97 (s40-25). Though taxpayers can choose their own ‘effective lives’ s40-100 allows the Commissioner to determine effective lives, which are widely used as they avoid…

Superannuation – ‘Member Information Accounts’ under s390-5 – Commissioner’s determination of ‘Approved Form’ registered – applies from 1 July 2018

A superannuation related Legislative Instrument: the Taxation Administration Member Account Transaction Service – the Reporting of Information Relating to Superannuation Account Transactions 2018 was registered on 27.6.2018. The Deputy Commissioner – Superannuation made the determination on 24 May 2018, but it was a little over a month until it was registered. The Determination will apply…

PR 2018/6 – Investment in Chan & Naylor Property Investor Trust – interest deductible and Part IVA doesn’t apply

On Wed 27.6.2018, the ATO released Product Ruling PR 2018/6 (Deductibility of interest in relation to an investment in a Chan & Naylor Property Investor Trust). This ruling considers the tax consequences of investing in a trust offered by CNIP Pty Ltd, using borrowings that are on arm’s length and commercial terms. In particular, it…