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

*Groves v FCT (No 4) – Stay of CGT appeal granted to ABC Learning Centres wife – pending Supreme Court ruling on alleged sale of shares [35]

In a judgment of the Federal Court dated 15 March 2012, the Court has granted a stay of Federal Court proceedings on a CGT issue pending conclusion of related proceedings in the Supreme Court of Qld. The stay was granted until the earlier of resolution of the Supreme Court proceeding or 1 March 2014 or…

*Gashi & Anor v FCT – Husband fails onus to show asset betterment assessments and 75% penalties were excessive but wife’s evidence she was just a house wife was accepted [34]

The Federal Court has made orders concerning income tax assessments and penalties issued to husband and wife taxpayers for the 2000 to 2006 income tax years inclusive. The matter concerned default assessments (including 75% penalty with the 20% uplift for most years) issued by the Commissioner to the taxpayers following an audit in March 2010.…

*Barossa Vines Limited v FCT – Leave granted to amend application to contest ATO decision to withdraw product rulings [33]

The Federal Court has granted a company’s request to be granted leave to file an amended originating application in relation to the Commissioner’s decision to withdraw 3 product rulings that had been issued to the company. The rulings were withdrawn on the grounds that there was a “material difference” in the way in which the…

*DCT v Hua Wang Bank Berhad (No 3) & Ors – Wickenby matter: GIC remitted, but stay refused because foreign taxpayers would remit funds overseas [32]

The Federal Court has ordered that GIC be excised from assessments issued to several taxpayers, but that their application to stay the Commissioner’s proceedings against them (to enforce earlier summary judgments made against them by the Federal Court) be denied. In a judgment by Kenny J of the Federal Court on 25 November 2010, a…

*FCT v Traviati – matter remitted to AAT after it erred in remitting 5% penalty – it should decide ‘careless’ issue first and ‘reasonably arguable’ issue second – ‘harshness’ irrelevant given scheme of provisions [31]

The Federal Court has allowed the Commissioner’s appeal from the decision in AAT Case 2011 AATA 478, Re Traviati and FCT, in which the AAT remitted 5% shortfall penalties in relation to the denial of over $1.5m in deductions for investments in a retirement village investment scheme. The AAT remitted the penalty on the basis…

*MTAA Superannuation Fund (R G Casey Building) Property Pty Ltd v FCT – Taxpayer loses appeal re GST refund claims for supplies under amended pre-GST leases [30]

In a decision handed down on Wed 20.6.2012, the Full Federal Court has dismissed a taxpayer’s appeal from an AAT decision that had denied the taxpayer’s claim that supplies made under amended pre-GST leases during the relevant periods were GST-free pursuant to s 13 of the GST Transition Act. The taxpayer had claimed refunds totalling…

*FCT v Byrne Hotels – Commissioner can’t appeal decision that for $5m net value purposes an agent’s commission for the sale of a hotel counts [26]

The High Court, on Fri 8.6.2012, refused the Commissioner special leave to appeal against the Full Federal Court decision in FCT v Byrne Hotels Qld Pty Ltd [2011] FCAFC 127. The Full Federal Court decision had by majority confirmed that for the purposes of accessing the CGT small business concessions, a real estate agent commission…