Draft Taxation Ruling TD 2018/D3: Commissioner’s View

Draft Taxation Ruling TD 2018/D3: Commissioner’s View

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...
Draft Taxation Ruling TD 2018/D3: New Trust View

Draft Taxation Ruling TD 2018/D3: New Trust View

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...
Draft Taxation Ruling TD 2018/D3: No New Trust View

Draft Taxation Ruling TD 2018/D3: No New Trust View

This is part 1 of my three-part series commenting on Draft Taxation Ruling TD 2018/D3. In this article, I will focus on No New Trust View and will explain why, in my opinion, No New Trust View is an error. The second part will focus on the New Trust View and its...
ATO attacks Trust Splitting; Resettlement Back on the Table

ATO attacks Trust Splitting; Resettlement Back on the Table

The arrival of TD 2018/D3 on Trust Splitting disrupts the pleasant calm around trust variations since TD 2012/21 when the ATO seemed to throw its hands in the air post-Clark and say that almost anything done in accordance with powers under a trust deed is not a...
Why Bill Gates’​ Robot Tax is either Bad or Scary

Why Bill Gates’​ Robot Tax is either Bad or Scary

Bill Gates has suggested that in response to robots taking the jobs of humans, there should be a robot tax. As a tax lawyer who builds artificial intelligence (and known as the Taxinator), of course I am going to have some comments. His line of reasoning is that a...
Land Tax and SA Trusts – Beware!

Land Tax and SA Trusts – Beware!

Land Tax aggregation has long been a source of pain for South Australian landowners, who face the highest rate of Land Tax in Australia. One trap has been RevenueSA’s view on when two or more landholding trusts are sufficiently different to be disaggregated. The...
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