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...
Our Tax Training sessions for 2025 have now concluded for the year. We would like to sincerely thank everyone who attended and participated throughout the year. Tax Training will resume in 2026, where we will continue working through the Top 100 tax cases and...
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...
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...
