This session examines Ziegler v Commissioner of Taxation; Wellton Holdings Pty Ltd v Commissioner of Taxation (2025 ATC 20-983), with particular focus on the contracting issue arising from the 2009 Settlement Deed. The central question is whether an alleged breach of...
This session introduces the small business CGT concessions (SBCC) in Division 152 of the ITAA 1997 using Moloney v Commissioner of Taxation [2024] AATA 1483 as a worked example. The purpose is not to focus on valuation disputes, but to use Moloney as a practical...
This session examines the circumstances in which an asset originally acquired for capital purposes can later change its character and become trading stock. The discussion focuses on the role of taxpayer intention, objective conduct, and timing in determining when (and...
This session examines development company structuring through the lens of Taxpayer Alert TA 2026/1, which targets contrived property development arrangements between related parties that defer income recognition and exploit tax losses. The Alert is considered against...
This session examines Commissioner of Taxation v Roberts and Smith (1992) in the context of interest deductibility following Ure and Fletcher. The case considers how interest on partnership borrowings is to be characterised where borrowed funds were used to make...
This session examines Fletcher v Federal Commissioner of Taxation and its place in the deductibility framework under s 51(1) of the ITAA 1936 (now s 8-1 ITAA 1997). Building on Ronpibon Tin and Ure, the case addresses how deductibility is assessed where the outgoing...
