Development Company Structures and Why PCG 2026/D2 Is Wrong In my view the PCG is wrong. It misreads the substantive law. It assumes facts that are not true of the arrangements it targets. It offers an alternative postulate that is not an alternative postulate. This...
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...
Notwithstanding that a promissory note is a relatively simple instrument, it may be drawn incorrectly. Examples of this are Re Permewan [26] and Turner v O’Bryan-Turner, [27] both of which involved a “gift and loan back” scheme. A further analysis of these cases is...
There is a certain type of sub-trust over income that many trust deeds purport to create, and which the Federal Commissioner purports to allow. This is where a trust is established over the income distributed from another trust. This is problematic for the reasons...
Dangers Of Law Clerks With Checklists The discussion surrounding the dangers of automation typically centre on novel and futuristic application of Artificial Intelligence. Even if we are not worried about Skynet terminating humans, we worry about application of data,...
