Taxation Determination TD 2003/32 Income tax: what are the tax consequences for a taxpayer as a result of entering into a scrip loan and call option arrangement as described in Taxpayer Alert 2002/2?

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Taxation Determination TD 2003/28 Income tax: capital gains: does CGT event E4 in section 104-70 of the Income Tax Assessment Act 1997 happen if the trustee of a discretionary trust makes a non-assessable payment to: (a) a mere object; or (b) a default beneficiary?

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Taxation Determination TD 2003/27 Income tax: how is double taxation avoided in the following situations where a Controlled Foreign Company (CFC) pays a dividend to an attributable taxpayer: (a) Out of income or profits derived by the CFC during a statutory accounting period that are subject to attribution and paid after the end of the CFC’s statutory accounting period but before the end of the attributable taxpayer’s year of income? (b) Out of income or profits derived by the CFC during a statutory accounting period that are subject to attribution and paid both before the end of the CFC’s statutory accounting period and the attributable taxpayer’s year of income?

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Taxation Determination TD 2003/23 Income tax: When an additional tax loss is transferred pursuant to Subdivision 170-A of the Income Tax Assessment Act 1997 (ITAA 1997) from the same ‘loss company’ to the same ‘income company’ in respect of the same income year as a previous loss transfer, what is the amount to be specified in the written agreement to be made under paragraph 170-50(2)(b) of the ITAA 1997 for that transfer?

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Taxation Determination TD 2003/20 Income tax: is a deduction allowable to a reward provider under section 8-1 of the Income Tax Assessment Act 1997 (‘ITAA 1997’) when points are credited to a member under a ‘consumer loyalty program’?

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Taxation Determination TD 2003/17 Income tax: is the addition of a nominal amount to the price of hired goods sufficient to satisfy the requirement in subparagraph (a)(ii) of the definition of ‘hire purchase agreement’ in subsection 995-1(1) of the Income Tax Assessment Act 1997 (‘the Act’) and so bring the hiring arrangement within the treatment under Division 240?

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Taxation Determination TD 2003/16 Income tax: does Division 240 of the Income Tax Assessment Act 1997 (“the Act”) apply to a hire purchase agreement if there is a notional buyer but no notional seller that is a party to that agreement?

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Taxation Determination TD 2003/15 Income tax: are the establishment costs incurred by a taxpayer in entering into a sale and leaseback of a capital asset deductible to the taxpayer under section 8-1 of the Income Tax Assessment Act 1997 (‘the ITAA 1997 Act’)?

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Taxation Determination TD 2003/11 Income tax: is expenditure incurred by an entity in obtaining valuations for the purposes of either entering into a consolidated group as a subsidiary member, or working out the future income tax liability of a consolidated group of which it would be a subsidiary member an allowable deduction to that entity under section 25-5 of the Income Tax Assessment Act 1997 ?

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Taxation Determination TD 2003/10 Income tax: is expenditure incurred by a head company in obtaining valuations in respect of the formation of a consolidated group or entities joining a consolidated group an allowable deduction under section 25-5 of the Income Tax Assessment Act 1997 ?

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Taxation Determination TD 2003/9 Income tax: is a taxpayer entitled to an income tax deduction for purported partnership losses claimed to have been incurred as a result of entering a prepaid service warrant arrangement as described in Taxpayer Alert 2002/5?

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Taxation Determination TD 2003/3 Income tax: Can Part IVA of the Income Tax Assessment Act 1936 (the ‘1936 Act’) apply to a ‘Capital Gains Tax reduction arrangement’ of the type described in this Taxation Determination?

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Taxation Determination TD 2003/1 Income tax: capital gains: can the first element of the cost base of a CGT asset in subsection 110-25(2) of the Income Tax Assessment Act 1997 include money paid or property given to an entity other than the one from which the asset was acquired?

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