On 10 October 2012, the High Court heard the taxpayer’s appeal against the Full Federal Court decision in Mills v FCT [2011] FCAFC 158. The Court reserved its decision but has released a transcript of the hearing – [2012] HCATrans 259.
The Full Federal Court had confirmed, by majority, that the “imputation benefit” scheme provisions in s 177EA of the ITAA 1936 applied to cancel franking credits that arose to the taxpayer from distributions paid on “debt-like” securities (Perpetual Exchangeable Resaleable Listed Securities V (“PERLS V Securities”)) he had subscribed for in the Commonwealth Bank.
[LTN 199, 15/10]