Taxation Determination TD 2004/D80W – Withdrawal Income tax: consolidation: capital gains and losses: does a capital gain arise under CGT event C2 when the amount received in payment of a foreign currency denominated trade receivable exceeds its tax cost setting amount?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Taxation Determination TD 2004/D85W – Withdrawal Income tax: consolidation: can the head company of a consolidated group claim a deduction, under section 8-1 of section 25-95 of the Income Tax assessment Act 1997, for the tax cost setting amount of partly performed work which has not yet given rise to a recoverable debt?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Taxation Determination TD 2004/D75W – Withdrawal Income tax: consolidation: can the head company of a consolidated group claim a deduction, under section 8-1 of the Income Tax Assessment Act 1997, for a consumable’s tax cost setting amount where: (a) an entity acquired the consumable before it became a subsidiary member of the consolidated group (the joining time); (b) the expenditure incurred in purchasing the consumable was deductible by the entity in the income year in which it was incurred; and (c) at the joining time, some or all of the consumable remained on-hand?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Taxation Determination TD 2004/D74W – Withdrawal Income tax: consolidation: can the head company of a consolidated group claim a deduction, following Taxation Ruling IT 333, for a consumable’s tax cost setting amount when the consumable is used, where: (a) an entity acquired the consumable before it became a subsidiary member of the consolidated group (the joining time); and (b) at the joining time, some of the consumable remained on-hand and its expenditure had not been fully deducted?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D73W – Withdrawal Income tax: consolidation: capital gains: which entity acquires a CGT asset, and when, if a contract to acquire the asset is entered into by a subsidiary member of a consolidated group and the contract settles after the subsidiary has left the group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D72W – Withdrawal Income tax: consolidation: capital gains: to which entity does a CGT event happen, and when, if a contract to sell a CGT asset entered into by an entity before it joins a consolidated group as a subsidiary member settles after joining?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D71W – Withdrawal Income tax: consolidation: capital gains: which entity acquires a CGT asset, and when, if a contract to acquire the asset is entered into by an entity before it joins a consolidated group as a subsidiary member and the contract settles after joining?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D91 Income tax: consolidation: is Australian currency, where it is taken to be foreign currency under section 960-80 of the Income Tax Assessment Act 1997 for the purposes of the functional currency provisions, treated as a retained cost base asset under the consolidation regime?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D90 Income tax: consolidation: is a unit in a cash management trust a retained cost base asset?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D89 Income tax: section 8-1 of the Income Tax Assessment Act 1997: capital protected loan facility with a call option writing feature: interest deductibility

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D88 Income tax: section 8-1 of the Income Tax Assessment Act 1997: capital protected loan facility with a trading feature: interest deductibility

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D87 Income tax: section 8-1 of the Income Tax Assessment Act 1997: capital protected loan facility with a reset feature: interest deductibility

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D86 Income tax: section 8-1 of the Income Tax Assessment Act 1997: refinancing a capital protected loan facility: interest deductibility

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D84 Income tax: does subsection 23AG(2) of the Income Tax Assessment Act 1936 apply where foreign earnings are exempt from tax in the foreign country for a reason listed in that subsection as well as a reason not listed?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D83 Income tax: does subsection 23AG(2) of the Income Tax Assessment Act 1936 apply where foreign earnings are exempt from tax in a foreign country for one or more of the reasons listed in that subsection and there is no additional reason for exempting that income?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D82 Income tax: will Part IVA of the Income Tax Assessment Act 1936 always apply if a business (including a personal services business) pays superannuation contributions that are considerably in excess of the value of the services provided by the employee?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

TD 2004/D85 (Withdrawn) – Income tax: consolidation: can the head company of a consolidated group claim a deduction, under section 8-1 or section 25-95 of the Income Tax Assessment Act 1997, for the tax cost setting amount of partly performed work which has not yet given rise to a recoverable debt?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D81 Income tax: consolidation: will a choice to consolidate under Part 3-90 of the Income Tax Assessment Act 1997 affect the method of income recognition of the consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D80 Income tax: consolidation: capital gains and losses: does a capital gain arise under CGT event C2 when the amount received in payment of a foreign currency denominated trade receivable exceeds its tax cost setting amount?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D74 Income tax: consolidation: can the head company of a consolidated group claim a deduction, following Taxation Ruling IT 333, for a consumable’s tax cost setting amount when the consumable is used, where: (a) an entity acquired the consumable before it became a subsidiary member of the consolidated group (the joining time); and (b) at the joining time, some of the consumable remained on-hand and its expenditure had not been fully deducted?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D75 Income tax: consolidation: can the head company of a consolidated group claim a deduction, under section 8-1 of the Income Tax Assessment Act 1997, for a consumable’s tax cost setting amount where: (a) an entity acquired the consumable before it became a subsidiary member of the consolidated group (the joining time); (b) the expenditure incurred in purchasing the consumable was deductible by the entity in the income year in which it was incurred; and (c) at the joining time, some or all of the consumable remained on-hand?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D77 Income tax: does a resident of a country with which Australia has a Tax Treaty, have a permanent establishment solely from the sale of trading stock through an internet website hosted by an Australian resident internet service provider?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D78 Income tax: is the income derived from a property syndicate that is structured to comply with the requirements of the managed investment scheme provisions of the Corporations Act 2001 taxable as net income of a trust estate under Division 6 of Pt III of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D79 Income tax: consolidation: does the phrase ‘could be recognised in the joining entity’s statement of financial position’ in subsection 705-90(2) of Income Tax Assessment Act 1997 refer to the application of accounting policies consistent with the established accounting framework in preparing an entity’s notional statement of financial position as at the joining time?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D14W – Withdrawal Income tax: consolidation: capital gains: is the period of ownership of an asset by a subsidiary member who brings it into the consolidated group taken into account in determining whether the head company has continuously owned the asset for the purposes of the small business 15 year exemption in Subdivision 152-B of the Income Tax Assessment Act 1997?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D71 Income tax: consolidation: capital gains: which entity acquires a CGT asset, and when, if a contract to acquire the asset is entered into by an entity before it joins a consolidated group as a subsidiary member and the contract settles after joining?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D73 Income tax: consolidation: capital gains: which entity acquires a CGT asset, and when, if a contract to acquire the asset is entered into by a subsidiary member of a consolidated group and the contract settles after the subsidiary has left the group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D72 Income tax: consolidation: capital gains: to which entity does a CGT event happen, and when, if a contract to sell a CGT asset entered into by an entity before it joins a consolidated group as a subsidiary member settles after joining?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D68 Income tax: consolidation: capital gains: does an entity permanently lose its status as an ‘originating company’, in respect of a deferral event in subsection 170-255(1) of the Income Tax Assessment Act 1997, when the entity becomes a subsidiary member of a consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D69 Income tax: consolidation: capital gains: does the deregistration of a subsidiary member of a consolidated group cause a ‘new event’ to happen under paragraph 170-275(1)(a) of the Income Tax Assessment Act 1997 if, before it joined that group, a transfer of shares in the subsidiary was a ‘deferral event’ under section 170-255 and group’s head company is the ‘originating company’ for the deferral event?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D70 Income tax: consolidation: capital gains: can the exemption in section 152-125 of the Income Tax Assessment Act 1997 apply to a payment made by the head company of a consolidated group to a CGT concession stakeholder of the head company in respect of a capital gain made on the disposal of an asset legally owned by a subsidiary member of the group for which the head company obtained the small business 15 year exemption?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D67 Income tax: consolidation: capital gains: if an entity makes a capital gain prior to becoming a subsidiary member of a consolidated group, can it choose to apply the small business replacement asset roll-over under Subdivision 152-E of the Income Tax Assessment Act 1997 if it acquires a replacement asset after it has joined the consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D65 Income tax: If a shareholder borrows from a private company under a clause in the company’s constitution setting out the terms on which such loans are to be made, is there a ‘written agreement’ for the purposes of paragraph 109N(1)(a) of Division 7A of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D66 Income tax: are payments to a volunteer respite carer to cover expenses of providing respite care for a disabled person assessable income?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D64 Income tax: consolidation: does the continuing majority-owned entity test in subsections 701A-1(1) and 701A-1(2) of the Income Tax (Transitional Provisions) Act 1997 require tracing through interposed entities to the ultimate beneficial owners to determine whether there has been a change in the majority ownership of an entity during the period from 27 June 2002 until the entity becomes a subsidiary member of a consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D63 Income tax: consolidation: if a transitional group has a non-chosen subsidiary in which all membership interests of the head company are held indirectly through a chosen transitional entity, and the non-chosen subsidiary has accrued profits, can an adjustment arise under section 705-160 of the Income Tax Assessment Act 1997 when working out the head company adjusted allocable amount under section 701-20 of the Income Tax (Transitional Provisions) Act 1997 for another non-chosen subsidiary?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D62 Income tax: consolidation: can an amount be included in the step 1 amount as well as the step 2 amount of the allocable cost amount calculation in section 705-60 of the Income Tax Assessment Act 1997?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D61 Income tax: consolidation: can section 705-80 of the Income Tax Assessment Act 1997 apply to a liability (or a change in a liability) that is recognised for accounting purposes because of an event that occurred after the joining time that provides new evidence of conditions that existed at the joining time?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D59 Income tax: consolidation: is there any apportionment under section 707-335 of the Income Tax Assessment Act 1997 to the limits calculated under subsection 707-350(3) of the Income Tax (Transitional Provisions) Act 1997 regarding the utilisation of losses?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D60 Income tax: consolidation: does the phrase ‘is taken into account at a later time’ in paragraph 705-80(1)(a) of the Income Tax Assessment Act 1997 require that an accounting liability, or a change in the amount of an accounting liability, of a joining entity that is first recognised after the joining time be examined when determining whether or not section 705-80 of that Act applies?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D58 Income tax: consolidation: where the head company and a chosen transitional entity in a consolidated group hold separate membership interests in a non-chosen subsidiary, how does the group calculate the allocable cost amount for the non-chosen subsidiary?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D57 Income tax: consolidation: life insurance: do sections 705-75 and 705-80 of the Income Tax Assessment Act 1997 apply to a policy liability that has been valued under section 713-520 for the purposes of working out step 2 of the allocable cost amount for a joining entity that is a life insurance company?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D56 Income tax: consolidation: is an adjustment under section 705-160 of the Income Tax Assessment Act 1997 required where the relevant membership interests are in a chosen transitional entity with losses?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D50 Income tax: consolidation: can the head company of a transitional group make a capital loss under section 104-500 (CGT event L1) of the Income Tax Assessment Act 1997 in respect of a chosen transitional entity?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D55 Income tax: consolidation: general insurance: do subsections 705-75(1) and 705-80(1) of the Income Tax Assessment Act 1997 apply to any part of an accounting liability for outstanding claims for the purposes of working out step 2 of the allocable cost amount for a joining entity that is a general insurance company?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D54 Income tax: for the condition outlined in subsection 707-328(4) of the Income Tax (Transitional Provisions) Act 1997, are Subdivisions 170-A and 170-B of the Income Tax Assessment Act 1997 applied as if they had not been amended by Schedule 3 to Act 68 of 2002, to only provide for loss transfers involving an Australian branch of a foreign bank?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D53 Income tax: consolidation: Division 7A: if a private company, as a member of a consolidated group, makes a payment, a loan or forgives a debt to a shareholder (or shareholder’s associate), that is also a member of the consolidated group, does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 prevent the application of Division 7A of the Income Tax Assessment Act 1936 to the transaction?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D52 Income tax: consolidation: Division 7A: if a private company that is a head company or subsidiary member of a consolidated group makes a payment or a loan, or forgives a debt to a shareholder (or shareholder’s associate) external to the consolidated group, does the single entity rule apply to the calculation of the distributable surplus under section 109Y of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D51 Income tax: consolidation: when calculating step 2 of the allocable cost amount for a joining entity, do section 705-75 or 705-80 of the Income Tax Assessment Act 1997 apply to a liability covered by subsection 705-70(2)?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D44 Income tax: what amount of deduction is available under section 40-25 of the Income Tax Assessment Act 1997 for the decline in value of copyright in patient records in respect of arrangements similar to those described in Taxpayer Alert 2004/5?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D49 Income tax: consolidation: can a head company of a consolidated group satisfy paragraph 25-35(1)(b) of the Income Tax Assessment Act 1997 for money lent by an entity in the ordinary course of its business of lending money where the entity joins the consolidated group and the debt is later written off as bad?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D48 Income tax: consolidation: are the voting interests in a foreign company held by a subsidiary member of a consolidated group treated as being voting interests of the head company of the group when determining whether section 23AJ of the Income Tax Assessment Act 1936 applies to a dividend paid to the group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D47 Income tax: can Division 16E of Part III of the Income Tax Assessment Act 1936 apply to a head company of a consolidated group where an intra-group income stream is assigned by a member of the group to a non-member?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D46 Income tax: can Division 16E of Part III of the Income Tax Assessment Act 1936 apply to a head company of a consolidated group where the principal of an intra-group loan is assigned by a member of the group to a non-member?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D45 Income tax: can the assignment of an intra-group debt or income stream to an entity that is not a member of the consolidated group give rise to a debt interest for the head company of the group under Division 974 of the Income Tax Assessment Act 1997?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D43 Income tax: consolidation: general insurance: are accounting liabilities for unearned premiums adjusted under subsections 705-75(1) and 705-80(1) of the Income Tax Assessment Act 1997 for the purposes of working out the allocable cost amount for a joining entity that is a general insurance company?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D21 Income tax: consolidation: capital gains: does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 mean that section 124-784 does not apply to the consolidated group in relation to shares issued by a subsidiary member to the head company under a scrip for scrip arrangement?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D42 Income tax: consolidation and capital gains tax: Does CGT event A1 in section 104-10 of the Income Tax Assessment Act 1997 happen to the head company of a consolidated group when a subsidiary member transfers a licence, granted to it by another member, to a non-group entity for no capital proceeds

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D39 Income tax: consolidation tax cost setting rules: are taxed profits considered before untaxed profits when determining which profits are included in the step 3 (subsection 705-90(3)) amount?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D38 Income tax: consolidation tax cost setting rules: step 3 of the allocable cost amount: should tax losses or net capital losses transferred to a joining entity be taken into account when determining whether an amount should be excluded at paragraph 705-90(6)(b)?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D37 Income tax: consolidation tax cost setting rules: step 4 of the allocable cost amount: should tax losses or net capital losses transferred to a joining entity be taken into account when determining whether there will be a subtraction at subparagraph 705-95(b)(ii)?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D36 Income tax: consolidation tax cost setting rules: how do you work out the amount subtracted at step 5 of the allocable cost amount where the loss taken into account under subsection 705-100(1) may also reduce the step 3 amount?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D35 Income tax: consolidation tax cost setting rules: should distributions of profits accrued to the joined group that recoup losses accrued to the group be counted when determining the step 4 amount of the allocable cost amount on formation of a transitional consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D41 Income tax: consolidation: is regard taken of intra-group money lending transactions or dealings in determining if the head company of a consolidated group is carrying on business as a money lender?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D34 Income tax: consolidation tax cost setting rules: will an amount be subtracted under step 4 of the allocable cost amount under subparagraph 705-95(b)(ii) of the Income Tax Assessment Act 1997 where there has been a distribution of profits accrued to the joined group that recouped losses accrued to the group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D33 Income tax: consolidation tax cost setting rules: step 3 of the allocable cost amount (ACA): how do you work out the paragraph 705-90(6)(b) amount where only some of the undistributed profits have recouped losses prior to the joining time?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D32 Income tax: consolidation tax cost setting rules: step 3 of the allocable cost amount: is the ‘retained profits’ amount referred to in subsection 705-90(2) a cumulative retained profits balance?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D31 Income tax: consolidation tax cost setting rules: should profits that accrue to a consolidated group be counted under step 3 of the allocable cost amount where those profits recouped non-economic losses that accrued to the group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D30 Income tax: consolidation tax cost setting rules: Are distributions paid up a chain of entities sourced from profits in a lower-tier entity that did not accrue to the joined group added at step 3 of the entry allocable cost amount (ACA) of the higher-tier entity?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D29 Income tax: consolidation: capital gains: does the determination of a capital gain or loss under section 104-530 (CGT event L7) of the Income Tax Assessment Act 1997 require a full reconstruction of the allocable cost amount at the joining time in relation to the relevant liability?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D28 Income tax: consolidation: capital gains: does section 104-530 (CGT event L7) of the Income Tax Assessment Act 1997 only apply to a liability that an entity has when it joins a consolidated group and the entity has an allocable cost amount worked out for it?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D26 Income tax: consolidation: capital gains: does section 104-530 (CGT event L7) of the Income Tax Assessment Act 1997 apply to amounts of a liability that accrue after the time that the entity with the liability joins a consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D27 Income tax: consolidation: capital gains: does section 104-530 (CGT event L7) of the Income Tax Assessment Act 1997 apply to the later discharge of a liability owed by an entity that joins a consolidated group to a member of that group (intra-group liability)?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D24 Income tax: consolidation: capital gains: does section 104-40 (CGT event D2) of the Income Tax Assessment Act 1997 apply to the head company of a consolidated group where an option is granted within the consolidated group and subsequently transferred to a third party?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D23 Income tax: consolidation: capital gains: does a CGT event happen to the head company of a consolidated group if a debt is created within the consolidated group and subsequently transferred to a third party?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D19 Income tax: consolidation: capital gains: does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 apply in determining whether the consequences in Subdivision 125-C apply to the head company of a consolidated group where one or more subsidiary members hold ownership interests in an entity outside the group that is being demerged?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D18 Income tax: consolidation: capital gains: for the purposes of Subdivision 125-C of the Income Tax Assessment Act 1997, can the head company of a consolidated group meet the requirements of a demerging entity in subsection 125-70(7) where, under a demerger, the shares held in a subsidiary member of a group are transferred to the head company’s shareholders?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D16 Income tax: consolidation: capital gains: if a subsidiary member of a consolidated group sells an asset which is taken for income tax purposes to have been disposed of by the head company, is the controlling individual condition in paragraphs 152-110(1)(c) or 152-305(2)(b) of the Income Tax Assessment Act 1997 applied to the head company of the consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D14 Income tax: consolidation: capital gains: is the period of ownership of an asset by a subsidiary member who brings it into the consolidated group taken into account in determining whether the head company has continuously owned the asset for the purposes of the small business 15 year exemption in Subdivision 152-B of the Income Tax Assessment Act 1997 ?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D12 Income tax: consolidation: capital gains: does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 affect the application of CGT event I1 in section 104-160 if a company which is a subsidiary member of a consolidated group stops being an Australian resident?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D22 Income tax: does paragraph 251L(1)(b) of the Income Tax Assessment Act 1936 prevent persons other than registered tax agents from giving advice about a taxation law?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D20 Income tax: consolidation: capital gains: if a subsidiary member of a consolidated group acquires shares in a non-consolidated company (original company) under a scrip-for-scrip arrangement, is the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 relevant in determining the eligibility for rollover of shareholders in the original company?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D17 Income tax: consolidation: capital gains: does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 affect the application of the controlling individual test in paragraph 152-10(2)(a) when a CGT event happens to a share or trust interest that is a membership interest in a subsidiary member (company or trust) of a consolidated group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D15 Income tax: consolidation: capital gains: does the transfer of an asset between members of a consolidated group affect the ownership period of the head company for the purposes of applying the small business 15 year exemption in Subdivision 152-B of the Income Tax Assessment Act 1997 ?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D13 Income tax: consolidation: capital gains: for the purposes of the capital gains tax rules in Parts 3-1 and 3-3 of the Income Tax Assessment Act 1997, is the head company of a consolidated group taken to have acquired an asset, which a subsidiary member brings to the group, at the same time that the subsidiary member acquired it?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D11 Income tax: consolidation: capital gains: if membership interests in a subsidiary member of a consolidated group are sold to a purchaser outside the group under a contract made while the subsidiary was a member of the group, does CGT event A1 in section 104-10 of the Income Tax Assessment Act 1997 happen when the contract was made?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D10 Income tax: consolidation: capital gains: does CGT event A1 in section 104-10 of the Income Tax Assessment Act 1997 happen to the head company of a consolidated group if an asset is sold by a subsidiary member to an entity outside the group?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D9 Income tax: is a deduction available in respect of capital expenditure incurred after 30 June 2001 in obtaining or in seeking to obtain the grant or extension of the term of a patent, the registration or extension of the registration period of a design, or the registration of a copyright under section 68A of the Income Tax Assessment Act 1936 or Division 40 of the Income Tax Assessment Act 1997?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D7 Income tax: can section 79D of the Income Tax Assessment Act 1936 operate to limit deductions available under Division 10B or Division 10BA of Part III of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D8 Income tax: Does expenditure on the acquisition of financial securities satisfy the ‘expended directly’ requirement of Division 10BA of Part III of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D6 Income tax: Does the payment of a ‘commercial debt’ by a guarantor, pursuant to a pre-existing guarantee, constitute forgiveness of the debt under section 245-35 of Schedule 2C of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D5 Income tax: Where a fringe benefits tax liability is deductible to a taxpayer under section 8-1 of the Income Tax Assessment Act 1997, is a later refund or reduction of that liability, as a result of an amended fringe benefits assessment, an assessable recoupment for the purposes of subsection 20-20(3) that must be included in the taxpayer’s assessable income under subsection 20-35(1)?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D4 Income tax: Where the Commissioner makes or amends a fringe benefits tax assessment for a fringe benefits tax year, when does the taxpayer incur an outgoing for the purposes of section 8-1 of the Income Tax Assessment Act 1997 for the fringe benefits tax assessed?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D3 Income tax: capital gains: are input tax credits excluded from a CGT asset’s cost base and reduced cost base worked out under sections 110-25 and 110-55 of the Income Tax Assessment Act 1997 and from other equivalent amounts used in working out a capital gain or loss?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D2 Income tax: is there a deemed assessment under section 166A of the Income Tax Assessment Act 1936 when a company lodges a ‘non-taxable return’ for a year of income?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D1 Income tax: For Off-Market Share Buy-Backs of listed shares, whether the buy-back price is set by tender process or not, what is the market value of the share for the purposes of subsection 159GZZZQ(2) of the Income Tax Assessment Act 1936?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

Draft Taxation Determination TD 2004/D76 Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, does an issuing company have an effectively non-contingent obligation to provide a financial benefit by way of periodic interest returns on an interest bearing convertible note from the time that it can be converted at the issuing company’s option into ordinary shares in that company?

This area is for member access only. To become a member, please visit our Easy As Plans & Pricing     
Read More

EASY AS TAX FINDER

CROUCH | TOUCH | PAUSE | ENGAGE

Easy As Tax Finder aims to make your ATO Public Tax Rulings and State and Territory Tax Rulings search as easy as possible. Coupled with our monthly recorded Tax webinar program delivered by highly trained tax professionals and tax practitioners – Easy As Tax Finder keeps you on top of Tax – all in one easy to access platform, at your fingertips 24/7.

CONTACT US

02 8249 8105
info@easyastaxfinder.com.au
Level 12, 95 Pitt Street, Sydney, NSW 2000, Australia
© Copyright 2020 - EasyAsTaxFinder - All Rights Reserved
Powered By :  Tight 5 Solutions
Developed By :  Consult 2 Manage
linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram
Send this to a friend