Draft Taxation Determination TD 2006/D40 Income tax: imputation: franked distributions: qualified persons: does an entity have to be a qualified person within the meaning of Division 1A of Part IIIAA of the Income Tax Assessment Act 1936 to avoid the application of paragraphs 207-145(1)(a) and 207-150(1)(a) of the Income Tax Assessment Act 1997 in respect of a franked distribution made directly or indirectly to the entity on or after 1 July 2002?

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Draft Taxation Determination TD 2006/D46 Income tax: consolidation: in applying the statutory cap in section 705-40 (tax cost setting amount for reset cost base assets held on revenue account) of the Income Tax Assessment Act 1997, does the definition of revenue asset in section 977-50 of that Act include any CGT asset, a hypothetical realisation of which would have an amount reflected in the joining entity’s taxable income (disregarding the single entity rule), otherwise than solely as a capital gain or capital loss?

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Draft Taxation Determination TD 2006/D45 Income tax: is the ‘applicable functional currency’ for the head company of a consolidated group determined by looking at the ‘accounts’ of all the members of the consolidated group, for the purposes of item 1 of subsection 960-60(1) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D44 Income tax: should a taxpayer who has incurred a tax loss or made a net capital loss for an income year retain records relevant to the ascertainment of that loss only for the record retention period prescribed under income tax law?

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Draft Taxation Determination TD 2006/D39 Income tax: consolidation: if a member of a consolidated group is reinstated under section 601AH of the Corporations Act 2001 after having been deregistered, will it be taken to have continued to satisfy the membership requirements in section 703-15 of the Income Tax Assessment Act 1997 during the period between deregistration and reinstatement?

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Draft Taxation Determination TD 2006/D42 Income tax: consolidation: can a head company make a capital gain under CGT event L5 (section 104-520 of the Income Tax Assessment Act 1997) when a subsidiary member of the group is deregistered after liquidation?

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Draft Taxation Determination TD 2006/D41 Income tax: consolidation: subsidiary in liquidation – for the purposes of subsection 711-45(1) of the Income Tax Assessment Act 1997, is the amount of an unsatisfied liability owed to another member of the consolidated group (‘intra-group liability’) by a subsidiary member at the time it is deregistered equal to the market value of the corresponding asset of that other member?

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Draft Taxation Determination TD 2006/D43 Income tax: consolidation: in working out the market value of the goodwill of each business of an entity that becomes a subsidiary member of a consolidated group, should the value of related party transactions of each business of the entity be recognised on an arm’s length basis?

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Draft Taxation Determination TD 2006/D38 Income tax: consolidation: can a tax loss, transferred under section 707-120 of the Income Tax Assessment Act 1997 to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, satisfy the condition described in paragraph 707-350(1)(c) of the Income Tax (Transitional Provisions) Act 1997?

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Draft Taxation Determination TD 2006/D37 Income tax: consolidation: can the transfer of a tax loss under section 707-120 of the Income Tax Assessment Act 1997, to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, constitute a COT transfer?

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Taxation Determination TD 2006/D12W – Withdrawal Income tax: will a balancing adjustment amount arise under section 40-285 of the Income Tax Assessment Act 1997 if a balancing adjustment event, such as a sale, occurs for a depreciating asset before the taxpayer uses the asset, or has it installed ready for use, for any purpose?

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Draft Taxation Determination TD 2006/D36 Income tax: capital gains tax: is a ‘policy of insurance on the life of an individual’ in section 118-300 of the Income Tax Assessment Act 1997 limited to a life insurance policy within the common law meaning of that expression?

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Draft Taxation Determination TD 2006/D35 Income tax: are certain payments to a volunteer foster carer to provide foster care assessable income?

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Draft Taxation Determination TD 2006/D24 Income tax: capital gains: can the clause ‘the relevant business ceased to be carried on’ in subparagraph 152-35(a)(ii) of the Income Tax Assessment Act 1997 be satisfied in the case of a taxpayer who sold the business to another?

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Draft Taxation Determination TD 2006/D34 Income tax: capital gains: small business concessions: is an entity that has a ‘controller’ under section 152-30 of the Income Tax Assessment Act 1997 necessarily a small business CGT affiliate under paragraph 152-25(1)(b) of the Income Tax Assessment Act 1997 of that ‘controller’?

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Draft Taxation Determination TD 2006/D33 Income tax: capital gains: small business concessions: is the part of a payment which is a small business 50% reduction amount a non-assessable part under CGT event E4 in section 104-70 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D32 Income tax: capital gains: is a bank account or cash on hand included in the numerator of the ‘80% test’ calculation in paragraph 152-40(3)(b) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D31 Income tax: capital gains: are there any circumstances in which the premises used in a business of providing accommodation for reward may satisfy the active asset test in section 152-35 of the Income Tax Assessment Act 1997 notwithstanding the exclusion in paragraph 152-40(4)(e) of the Income Tax Assessment Act 1997 for assets whose main use is to derive rent?

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Draft Taxation Determination TD 2006/D30 Income tax: capital gains: small business concessions: must a taxpayer receive actual capital proceeds from a CGT event to qualify for the small business retirement exemption under Subdivision 152-D of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D29 Income tax: capital gains: small business concessions: can trustees or members of a complying superannuation fund ‘control’ the superannuation fund in the way described in section 152-30 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D28 Income tax: capital gains: small business concessions: does a person who has the power to remove the trustee of a discretionary trust and appoint a new trustee control the trust for the purposes of subparagraph 152-30(2)(c)(ii) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D27 Income tax: capital gains: small business concessions: what ‘liabilities’ are included in the calculation of the ‘net value of the CGT assets’ of an entity in the context of subsection 152-20(1) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D26 Income tax: capital gains: small business concessions: is the rollover of an eligible termination payment from a discretionary trust to a superannuation fund, in relation to an employee who is also a beneficiary of the trust, a ‘distribution of income or capital’ under subsection 152-55(3) of the Income Tax Assessment Act 1997 for the purposes of the controlling individual test?

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Draft Taxation Determination TD 2006/D25 Income tax: capital gains: small business concessions: can a share in a company or an interest in a trust qualify as an active asset under subsection 152-40(3) of the Income Tax Assessment Act 1997 if the company or trust owns interests in another entity that satisfies the ‘80% test’?

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Draft Taxation Determination TD 2006/D23 Income tax: capital gains: is a CGT asset that is leased by a taxpayer to a connected entity for use in the connected entity’s business an active asset under section 152-40 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D22 Income tax: capital gains: are all classes of shares (other than redeemable shares) issued by a company taken into account in determining if the company has a controlling individual under subsection 152-55(1) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D21 Income tax: is any part of an amount, which is otherwise deductible as a transport expense for travel between workplaces (one of which is a business), attributable to the relevant business activity under subsection 35-10(2) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D20 Income tax: how does a taxpayer work out the amount to be included in assessable income under section 27H of the Income Tax Assessment Act 1936 for a superannuation pension or annuity that is payable in a foreign currency?

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Draft Taxation Determination TD 2006/D19 Income tax: demergers: in reallocating the cost bases of ownership interests under a demerger, as required by subsection 125-80(2) of the Income Tax Assessment Act 1997, is there more than one method that produces a reasonable apportionment?

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Draft Taxation Determination TD 2006/D18 Income tax: consolidation: is a deferred tax liability recognised and measured in accordance with AASB 1020 (AAS 3) ‘Income Taxes’ (the 1999 standard) an accounting liability under subsection 705-70(1) where the 1999 standard was not adopted for the recognition and measurement of the liability for financial reporting purposes for the period within which the joining time occurred?

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Draft Taxation Determination TD 2006/D17 Income tax: are there circumstances when a balancing adjustment for a car is worked out under section 40-370 instead of section 40-285 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D16 Income tax: can section 160ZZZJ of Part IIIB of the Income Tax Assessment Act 1936 apply to interest entered in the accounting records of an Australian branch of a foreign bank if the interest relates to a borrowing the branch has obtained from a third party?

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Draft Taxation Determination TD 2006/D15 Income tax: what amounts are included in ‘establishment expenditure’ for the purposes of working out the decline in value of a horticultural plant under section 40-545 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D5ER – Erratum Income tax: where there is a disposal of foreign currency or a right to receive foreign currency and forex realisation event 1 happens, is the amount attributable to a currency exchange rate effect determined by subtracting the non-forex component of the capital gain (or loss) from the overall capital gain (or loss)?

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Draft Taxation Determination TD 2006/D13 Income tax: can a dividend, or part of a dividend, be non-assessable non-exempt income under both section 23AJ and section 23AI of the Income Tax Assessment Act 1936?

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Draft Taxation Determination TD 2006/D11 Income tax: does subsection 40-230(1) of the Income Tax Assessment Act 1997 reduce the first element of the cost of a car designed mainly for carrying passengers by the amount of any input tax credit the taxpayer is or becomes entitled to for the acquisition or importation of the car before the car limit is applied?

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Draft Taxation Determination TD 2006/D14 Income tax: can a dividend, or part of a dividend, be non-assessable non-exempt income under both section 23AJ and section 23AK of the Income Tax Assessment Act 1936?

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Draft Taxation Determination TD 2006/D12 Income tax: will a balancing adjustment amount arise under section 40-285 of the Income Tax Assessment Act 1997 if a balancing adjustment event, such as a sale, occurs for a depreciating asset before the taxpayer uses the asset, or has it installed ready for use, for any purpose?

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Draft Taxation Determination TD 2006/D10 Income tax: is a hearse ‘a car designed mainly for carrying passengers’ for the purposes of section 40-230 of the Income Tax Assessment Act 1997 and therefore subject to the car limit?

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Draft Taxation Determination TD 2006/D9 Income tax: foreign currency gains and losses: if a forex realisation gain is made under section 775-55 of the Income Tax Assessment Act 1997 upon payment for the acquisition of foreign currency denominated trading stock, is that gain ‘ordinary income’ as defined in section 6-10 of the Income Tax Assessment Act 1997 for the purposes of subsection 45-120(1) of Schedule 1 to the Taxation Administration Act 1953?

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Draft Taxation Determination TD 2006/D8 Income tax: for the purposes of Division 775 of the Income Tax Assessment Act 1997, does forex realisation event 2 and forex realisation event 4 occur when, on novation, a foreign currency-denominated debt is ended and a new party becomes either the creditor or debtor in the substituted debt?

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Draft Taxation Determination TD 2006/D7 Income tax: are margin payments made in respect of exchange-traded option and futures contracts deductible under section 8-1 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D6 Income tax: for the purposes of Division 775 of the Income Tax Assessment Act 1997, what forex realisation events happen to a creditor and a debtor, on the effective assignment by the creditor to a third party of a presently existing right to receive an amount under a foreign currency-denominated debt?

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Draft Taxation Determination TD 2006/D5 Income tax: where there is a disposal of foreign currency or a right to receive foreign currency and forex realisation event 1 happens, is the amount attributable to a currency exchange rate effect determined by subtracting the non-forex component of the capital gain (or loss) from the overall capital gain (or loss)?

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Draft Taxation Determination TD 2006/D4 Income tax: is a non-member spouse who is under 55 years of age entitled to a rebate under section 159SM or section 159SU of the Income Tax Assessment Act 1936 when a superannuation pension or ‘eligible annuity’ is split pursuant to an agreement or court order on marriage breakdown on a specified percentage basis?

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Draft Taxation Determination TD 2006/D3 Income tax: will the Commissioner exercise his discretion under subsection 27H(3) of the Income Tax Assessment Act 1936 in determining the deductible amount in relation to a superannuation pension or ‘eligible annuity’ split pursuant to an agreement or court order on marriage breakdown?

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Draft Taxation Determination TD 2006/D2 Income tax: consolidation: subsidiary in liquidation – are unsatisfied debts of a subsidiary at the time of deregistration, being debts owed to creditors outside of the consolidated group, accounting liabilities for the purposes of subsection 711-45(1) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2006/D1 Income tax: consolidation: will a subsidiary company that is deregistered cease to be a member of a consolidated group with the consequence that it is treated as a leaving entity for the purposes of Division 711 of the Income Tax Assessment Act 1997?

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