The taxpayer has applied for special leave to appeal to the High Court against the decision of the Full Federal Court in Sent v FCT [2012] FCAFC 187. The Full Federal Court had dismissed the taxpayer’s appeal and held that the full amount of accrued and unaccrued bonus entitlements of id=”mce_marker”1.6m that were instead paid into an executive share trust on the taxpayer’s behalf had been derived by the taxpayer as ordinary income.

[FJM Note:    there was a report about the Full Federal Court decision, the subject of this appeal, in last month’s edition of Morgan’s Tax Month.]

[LTN 21, 1/2/13]