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...
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...
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 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...
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...
This week we will read the High Court hearing transcript in Commissioner of Taxation v Bendel and focus on what the Court appears to be probing beyond Div 7A: the nature and source of trust entitlements. If the High Court does examine the nature of trust entitlements...
