The ATO has stuck to their guns on the view that a Trust Split creates a new trust (and hence a CGT Event), however they have made it clear that a separation of powers within a trust (which I call an ‘Internal Trust Split’) will not trigger CGT. An...
Given R&D is trending in Govt reviews, here are my ten thoughts on the R&D tax incentive, by a tax lawyer (Cartland Law) and AI developer (Ailira) who claims R&D himself The ‘Research Hypothesis’ model doesn’t fit software development....
The Draft Bill for the changes to Land Tax Aggregation in South Australia has been released, and as expected it is terrible news for taxpayers. The Government has invited submissions on the draft Bill by, 2 October 2019. In my view there are a number of reasons why it...
In the 2019-20 SA State Budget, there has been a further attack on landholding trusts. With the highest rate of land tax in the country, property owners have been repeatedly stung with changes that tax them in a manner that they would not have expected when they...
This is the last part of my three-part series commenting on Draft Taxation Ruling TD 2018/D3. In this article, I will focus on the CGT and TD 2018/D3. The previous parts of the series explained the differences between No New Trust View and New Trust View. WHY A NEW...
This is part 2 of my three-part series commenting on Draft Taxation Ruling TD 2018/D3. In this article, I will focus on the New Trust View and its consequence, and the last part of the series will be dedicated to discussing CGT and TD 2018/D3. The first part of the...
