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...
Bendel May Be More Interesting Than It Appears – Clarifying Present Entitlement Bendel is one of the most anticipated tax cases of the past couple of decades. Simply put, whether UPEs trigger a Div 7A deemed dividend is a matter that is consequential to every tax...
On 9th November 2023 the ATO has released web guidance in relation to decentralised finance and wrapping crypto transactions. I presented the below example over a year ago at seminars for The Tax Institute, private clients, and in submissions to Treasury. The ATO has...
10 Things I Hate About Your R&D Claim The Australian Government offers a generous incentive for Australian companies to conduct R&D activities in Australia. The ATO can refund up to 45% of your R&D expenditure. Such an attractive proposition leads many to...
There is a certain type of sub-trust over income that many trust deeds purport to create, and which the Federal Commissioner purports to allow. This is where a trust is established over the income distributed from another trust. This is problematic for the reasons...
