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Tax Training – 12/12/2025 – Llewellyn Wood: Ure v FCT, Business Operation & Deductibility of Outgoings

This week we discussed the fundamental basis for determining when a business is being operated, and when a business operator may deduct outgoings in relation to that business. We also discussed apportionment of interest costs and borrowing costs. Next week, we will...

Tax Training – 05/12/2025 – Llewellyn Wood: Ure v FCT and Deductibility of Borrowing Expenses

This session explores the deductibility of interest and borrowing expenses in a family and trust context. We will review Ure v FCT alongside section 8-1 and the borrowing expense rules (formerly s 51(1) and s 67 ITAA 1936).  Discussion Focus: How the Federal Court...

Tax Training – 28/11/2025 – Llewellyn Wood: Ronpibon Tin and section 8-1 of the ITAA 1997

This session explores the fundamentals of deductions for income tax purposes. We will review Ronpibon Tin and section 8-1 of the ITAA 1997.  Discussion Focus: The requirement that an expense be “incidental and relevant” to earning taxable income, and what this means...

Tax Training – 21/11/2025 – Adrian Cartland: Consultation on 16 Proposals for Reforming SA State Taxes

This session presents a draft set of 16 proposals for State Taxes reform, circulated for discussion and practitioner feedback before being finalised. These reforms aim to modernise South Australia’s tax administration by drawing on proven ATO systems and best...
Bendel May Be More Interesting Than It Appears – Clarifying Present Entitlement

Bendel May Be More Interesting Than It Appears – Clarifying Present Entitlement

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...

Tax Training – 14/11/2025 – Adrian Cartland: Bamford and Bendel – Fixing Present Entitlement through Payment and Proportion

Bamford resolved the proportionate approach to Division 6 by distinguishing between distributable and taxable income but did not clarify when entitlement arises. The coming High Court decision in Bendel is expected to examine whether beneficiaries cannot become...
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