This session moves past PCG 2026/D2 to examine the question that sits underneath it: when land is made available to a partnership but not contributed to it, what is the legal character of the accretions to that land produced by partnership activity, and what are the...
This session examines draft PCG 2026/D2, the ATO’s compliance framework for the application of Part IVA to related-party property development arrangements involving long-term construction contracts. The Guideline is the natural companion to TA 2026/1, discussed...
This session examines Sun Newspapers Ltd v Federal Commissioner of Taxation (1938) and its role in determining whether an outgoing is on capital or revenue account under s 51(1) (now s 8-1). Please see below link to case materials which is assumed reading in order to...
This session examines whether rigorous questioning can cross the line into bullying in professional environments. Using Plato’s Hippias Minor as a case study, the discussion considers Socrates’ method of questioning the sophist Hippias and whether the exchange...
This session examines Commissioner of Taxes (SA) v Executor Trustee and Agency Co of South Australia Ltd (Carden’s Case) (1938) 63 CLR 108 and its continuing significance for the concept of derivation under s 6-5 ITAA 1997. We will consider how the High Court...
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...
