Draft Taxation Determination TD 2011/D10W – Notice of Withdrawal Income tax: when considering the application of subsection 159GZZZQ(2) of the Income Tax Assessment Act 1936 to an exiting vendor practitioner-shareholder by a ‘no goodwill’ incorporated professional practice, will the Commissioner consider that the buy-back price is less than the market value of the shares merely because the price is calculated not to reflect the underlying goodwill of the company?

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Draft Taxation Determination TD 2011/D12 Income tax: what types of temporary absences from foreign service form part of a continuous period of foreign service under section 23AG of the Income Tax Assessment Act 1936?

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Draft Taxation Determination TD 2011/D11 Income tax: when is the shortfall interest charge incurred for the purposes of paragraph 25-5(1)(c) of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2011/D9 Income tax: Employee share schemes: If a share in a ‘no goodwill’ professional practice company is acquired by a practitioner-shareholder (or a new practitioner-shareholder), will the Commissioner accept, for the purposes of determining whether that acquisition was at a discount within the meaning of subsection 83A-20(1) of the Income Tax Assessment Act 1997, that the goodwill of the company can be taken to have no value?

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Draft Taxation Determination TD 2011/D10 Income tax: When considering the application of subsection 159GZZZQ(2) of the Income Tax Assessment Act 1936 to an exiting vendor practitioner-shareholder by a ‘no goodwill’ incorporated professional practice, will the Commissioner consider that the buy-back price is less than the market value of the shares merely because the price is calculated not to reflect the underlying goodwill of the company?

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Draft Taxation Determination TD 2011/D8 Income tax: does a taxpayer’s purpose of ‘paying their home loan off sooner’ mean that Part IVA of the Income Tax Assessment Act 1936 cannot apply to an ‘investment loan interest payment arrangement’ of the type described in this Taxation Determination?

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Draft Taxation Determination TD 2011/D7 Income tax: Division 7A: do the exclusion rules in Subdivision D of Division 7A of Part III of the Income Tax Assessment Act 1936 (ITAA 1936) necessarily impact on the deemed circumstances arising from Subdivision E of the ITAA 1936 and the consequent operation of Subdivision B of the ITAA 1936?

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Draft Taxation Determination TD 2011/D5 Income tax: will the gain or loss resulting from the expiration, sale, termination or exercise of a hedging financial arrangement to which a hedging financial arrangement election applies be determined and allocated in accordance with subsections 230-300(2) and 230-300(3) of the Income Tax Assessment Act 1997 where that expiration, sale, termination or exercise happens before an occurrence of an event listed in the table in section 230-305 of the Income Tax Assessment Act 1997?

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Draft Taxation Determination TD 2011/D6 Income tax: does the hedge effectiveness test under section 230-365 of the Income Tax Assessment Act 1997 require both retrospective and prospective testing for the purposes of the hedging financial arrangements method?

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Draft Taxation Determination TD 2011/D9W – Notice of Withdrawal Income tax: employee share schemes: if a share in a ‘no goodwill’ professional practice company is acquired by a practitioner-shareholder (or a new practitioner-shareholder), will the Commissioner accept, for the purposes of determining whether that acquisition was at a discount within the meaning of subsection 83A-20(1) of the Income Tax Assessment Act 1997, that the goodwill of the company can be taken to have no value?

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Draft Taxation Determination TD 2011/D4 Tax administration: what is a general administrative practice for the purposes of protection from administrative penalties and interest charges?

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Draft Taxation Determination TD 2011/D3 Income tax: capital gains tax: will the Commissioner accept that the shares in a ‘no goodwill’ incorporated professional practice have a market value of nil when considering the application of subsection 116-30(1) of the Income Tax Assessment Act 1997 to an admission or exit of a practitioner-shareholder from the practice for no consideration?

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Draft Taxation Determination TD 2011/D2 Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to a scheme designed to convert otherwise assessable interest income into non-assessable non-exempt dividends?

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Draft Taxation Determination TD 2011/D1 Income tax: does it follow merely from the fact that an investment has been made by a trustee that any gain or loss from the investment will be on capital account?

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