The High Court will deliver judgment in Commissioner of Taxation v Bendel on Wednesday, 10 June 2026. This week’s tax training will be the first in a series examining the decision. Bendel is one of the most anticipated tax cases of this century. The question...
This session continues last week’s discussion on vector-based accounting for trusts. The issue remains whether trust accounts should be understood as a single static balance sheet, or as a series of related but distinct accounts which separately express legal form,...
This session introduces vector-based accounting for trusts. The issue is whether trust accounts should be understood as a single static balance sheet, or as a series of related but distinct accounts which separately express legal form, income character, timing,...
Development Company Structures and Why PCG 2026/D2 Is Wrong In my view the PCG is wrong. It misreads the substantive law. It assumes facts that are not true of the arrangements it targets. It offers an alternative postulate that is not an alternative postulate. This...
This session continues last week’s discussion of Harvey v Harvey and s 106-5, and turns to the operation of partnerships as an income-splitting structure in a world where trust distributions are subject to a 30% minimum tax. With the Government’s recent...
Last week we turned to consider s 106-5 of the ITAA 1997 and the question of what CGT event occurs when a partner contributes an asset to a partnership without transferring legal title, and how the resulting gain or loss is attributed between the partners....
