Draft Taxation Determination TD 2007/D16W – Notice of Withdrawal Income tax: can section 177EA of the Income Tax Assessment Act 1936 apply to the issue of ‘dollar value’ convertible notes of the type described in this Taxation Determination?

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Draft Taxation Determination TD 2007/D20W – Notice of Withdrawal Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997, can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?

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Draft Taxation Determination TD 2007/D23 Fringe benefits tax: where an employer mistakenly pays to their employee an amount that the employee is not legally entitled to, but is obliged to repay, does the employer’s subsequent waiver of that obligation constitute a ‘debt waiver benefit’ under section 14 of the Fringe Benefits Tax Assessment Act 1986?

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Draft Taxation Determination TD 2007/D22 Fringe benefits tax: where an employer recognises they mistakenly paid to their employee an amount that the employee is not legally entitled to, but is obliged to repay, and afterwards allows the employee time to repay the amount, is there a ‘loan benefit’ under subsection 16(1) of the Fringe Benefits Tax Assessment Act 1986?

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Draft Taxation Determination TD 2007/D21 Income tax: are amounts mistakenly paid as salary or wages to employees (or as income support payments or worker’s compensation amounts to persons), to which they are not beneficially entitled, but are obliged to repay, ‘ordinary income’ under section 6-5 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2007/D20 Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997 can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?

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Draft Taxation Determination TD 2007/D19 Income tax: if a private company makes a loan to a shareholder or associate in an income year and the loan has not been fully repaid, what elements of the loan agreement need to be in writing for the purposes of paragraph 109N(1)(a) of Division 7A of Part III of the Income Tax Assessment Act 1936?

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Draft Taxation Determination TD 2007/D16 Income tax: can section 177EA of the Income Tax Assessment Act 1936 apply to the issue of ‘dollar value’ convertible notes of the type described in this Taxation Determination?

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Draft Taxation Determination TD 2007/D17 Income tax: if a private company provides trade credit to a shareholder (or their associate) on the usual terms it gives to parties at arm’s length, will a failure by the shareholder (or their associate) to repay the amount within the agreed payment term prevent section 109M of the Income Tax Assessment Act 1936 from applying?

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Draft Taxation Determination TD 2007/D15 Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend paid by a company (not being a Part X Australian resident) to the trustee of a trust, which then pays it to an Australian resident company beneficiary?

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Draft Taxation Determination TD 2007/D14 Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend when it is paid by a company (not being a Part X Australian resident) to an Australian resident company which receives it in its capacity as a partner in a partnership?

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Draft Taxation Determination TD 2007/D13 Income tax: holding period rule: is an embedded share option a position in relation to the share if it is exercisable by or against a party other than the issuer of the share?

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Draft Taxation Determination TD 2007/D12 Income tax: is a non-resident head lessor of substantial equipment liable for royalty withholding tax under subsection 128B(5A) of the Income Tax Assessment Act 1936 on lease payments it receives from a Singaporean resident who subleases that same equipment to an entity which operates it in Australia?

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Draft Taxation Determination TD 2007/D11 Income tax: will the hire of substantial equipment in Australia under a hire-purchase agreement create a deemed permanent establishment for a Singaporean resident hirer under Article 4(3)(b) of the tax treaty between Australia and Singapore as a result of the decision in McDermott Industries (Aust) Pty Ltd v. Federal Commissioner of Taxation [2005] FCAFC 67?

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Draft Taxation Determination TD 2007/D10 Fringe benefits tax: in determining whether a charitable institution is a rebatable employer for the purposes of paragraph 65J(1)(baa) of the Fringe Benefits Tax Assessment Act 1986, is the institution ‘established by a law of the Commonwealth, a State or a Territory’ under subsection 65J(3) of that Act when it is incorporated under either the Corporations Act 2001 or under a law of a State or Territory which relates to the incorporation of Associations?

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Draft Taxation Determination TD 2007/D9 Income tax: is income tax of a private company properly payable for an income year, but unpaid at the end of that year, a ‘present legal obligation’ for the purposes of the distributable surplus calculation under subsection 109Y(2) of Division 7A of Part III of the Income Tax Assessment Act 1936?

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Draft Taxation Determination TD 2007/D8 Income tax: what is a ‘present legal obligation’ of a private company for the purposes of subsection 109Y(2) of Division 7A of Part III of the Income Tax Assessment Act 1936?

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Draft Taxation Determination TD 2007/D7 Income tax: are bees kept for use in a honey production business trading stock as defined in section 70-10 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2007/D6 Income tax: do the active assets of a partnership, in which a foreign company is a partner, constitute active foreign business assets of the foreign company for the purposes of the capital gains tax participation exemption provisions contained in Subdivision 768-G of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2007/D4 Miscellaneous taxes: does paragraph 284-220(1)(e) of Schedule 1 to the Taxation Administration Act 1953 apply to increase the base penalty amount applicable to a subsection 284-75(3) penalty where the entity was liable to the same penalty for a previous accounting period?

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Draft Taxation Determination TD 2007/D3 Income tax: can a share in a company be a convertible interest by satisfying item 4 of the table in subsection 974-75(1) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2007/D2 Income tax: can the attribution regime relating to controlled foreign companies apply to an Australian entity that is a member of a foreign company limited by guarantee?

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Draft Taxation Determination TD 2007/D1 Income tax: does the notional assessable income of a controlled foreign company include an amount deemed to be a dividend under section 47A of the Income Tax Assessment Act 1936?

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