Taxation Determination TD 2005/54 Income tax: consolidation: asset cost setting rules: where the cost and value of the reset cost base assets of a joining entity are so small or trifling that they are de minimis, can they be ignored when determining whether a CGT event L4 loss is available under section 104-515 of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2005/53 Income tax: consolidation: exit tax cost setting rules: where an accounting liability added at subsection 711-45(1) of the Income Tax Assessment Act 1997 is modified by the operation of subsections 711-45(3) and (5), does the amount determined under subsection 711-45(5) override the adjustment made by subsection 711-45(3)?

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Taxation Determination TD 2005/52 Income tax: capital gains: can money paid for the purposes of the first element of the cost base in subsection 110-25(2) of the Income Tax Assessment Act 1997 and the reduced cost base under section 110-55 of the Income Tax Assessment Act 1997 include the amount of a liability extinguished under the doctrine of set-off?

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Taxation Determination TD 2005/51 Income tax: consolidation: can the transferee make more than one choice, under subsection 707-327(4) of the Income Tax (Transitional Provisions) Act 1997, to treat a value donor’s loss as being included in another bundle of losses?

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Taxation Determination TD 2005/50 Income tax: consolidation: can the transferee make a choice under subsection 707-327(4) of the Income Tax (Transitional Provisions) Act 1997 to treat part of a loss transferred, under Subdivision 707-A of the Income Tax Assessment Act 1997, from a value donor as being included in another bundle of losses?

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Taxation Determination TD 2005/49 Income tax: consolidation: can donations of modified market value to different real loss-makers from the same value donor, under multiple applications of the formula in subsection 707-325(3) of the Income Tax (Transitional Provisions) Act 1997, be ordered?

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Taxation Determination TD 2005/48 Income tax: consolidation: in applying the formula in subsection 707-325(3) of the Income Tax (Transitional Provisions) Act 1997 to more than one real loss-maker in relation to the same value donor, does the amount of the ‘value donor’s modified market value at initial transfer time’ remain unchanged?

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Taxation Determination TD 2005/47 Income tax: what do the words ‘can deduct’ mean in the context of those provisions in Division 110 of the Income Tax Assessment Act 1997 which reduce the cost base or reduced cost base of a CGT asset by amounts you ‘have deducted or can deduct’, and is there a fixed point in time when this must be determined?

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Taxation Determination TD 2005/46 Income tax: consolidation: what is the tax cost of an asset of a leaving entity that is only recognised upon the entity ceasing to be a subsidiary member of a consolidated group when the single entity rule ceases to apply?

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Taxation Determination TD 2005/45 Income tax: consolidation: what is the meaning of ‘liability owed’ in section 711-40 of the Income Tax Assessment Act 1997?

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TD 2005/44 Income tax: consolidation: cost setting: are the tax costs of the assets of a transitional foreign-held indirect subsidiary which is not a chosen transitional entity set when the entity becomes a member of a consolidated or MEC group?

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Taxation Determination TD 2005/43 Income tax: consolidation: cost setting: are the tax costs of assets of a subsidiary member of a consolidated or MEC group set if some of the subsidiary member’s membership interests are directly held by entities outside the group?

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Taxation Determination TD 2005/42 Income tax: consolidation: cost setting: if a consolidated or MEC group qualifies as a transitional group, can the head company choose to retain the existing tax values of the assets of all the subsidiary members of the group irrespective of whether or not they are transitional entities?

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Taxation Determination TD 2005/41 Income tax: consolidation: cost setting: do the assets of a transitional foreign-held subsidiary retain their existing tax values on formation of a consolidated or a MEC group?

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Taxation Determination TD 2005/40 Income tax: consolidation: membership: if an Australian resident entity satisfies all the conditions for being a member of a consolidatable or potential MEC group including, where appropriate, either section 701C-10 or section 701C-15 of the Income Tax (Transitional Provisions) Act 1997, can that entity remain outside the group when the group consolidates?

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Taxation Determination TD 2005/39 Income tax: consolidation: membership: can an Australian resident company qualify as an eligible tier-1 company of a MEC group if a foreign resident entity is interposed between the Australian resident company and the top company of the group?

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Taxation Determination TD 2005/38 Income tax: consolidation: membership: are the eligible tier-1 companies of a foreign-owned group required to form a single MEC group which includes all those eligible tier-1 companies?

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Taxation Determination TD 2005/37 Income tax: does subsection 23AG(2) of the Income Tax Assessment Act 1936 apply where a member of the Australian Defence Force is engaged in foreign service for a continuous period of at least 91 days as part of certain UN operations conducted under a UN agreement with a ‘host country’ which exempts from taxation in that country, the pay and emoluments received from the UN or from a participating State and on any income received from outside the host country?

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Taxation Determination TD 2005/35 Income tax: must an outgoing incurred by a supplier in deriving income from a taxable supply be apportioned when calculating the deduction allowable for the outgoing under section 8-1 of the Income Tax Assessment Act 1997, because some amount of the income relates to GST payable on a taxable supply, and is non-assessable non-exempt income?

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Taxation Determination TD 2005/29 Income tax: will Part IVA of the Income Tax Assessment Act 1936 always apply if a taxpayer who carries on a business (including a personal services business) pays superannuation contributions that do not exceed the age-based limits but are considerably in excess of the value of the services provided by the employee?

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Taxation Determination TD 2005/34 Income tax: what are the results for income tax purposes of entering into a profit washing arrangement as described in Taxpayer Alert TA 2005/1?

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Taxation Determination TD 2005/33 Income tax: does expenditure – which is a non-capital cost of ownership of a CGT asset – form part of the cost base of the asset, if it is a tax benefit in connection with a scheme to which the general anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936 apply?

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Taxation Determination TD 2005/28 Income tax: is the income of a property syndicate taxable as net income of a trust estate under Division 6 of Part III of the Income Tax Assessment Act 1936 where the syndicate is a registered managed investment scheme under the Corporations Act 2001 and the responsible entity holds the income producing property of the syndicate for scheme members as scheme property?

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Taxation Determination TD 2005/26 Income tax: does a taxpayer in a passive investment have day to day control over the operation of an agreement for the purposes of paragraph 82KZME(3)(b) of the Income Tax Assessment Act 1936?

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Taxation Determination TD 2005/25 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?

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Taxation Determination TD 2005/24 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?

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Taxation Determination TD 2005/23 Income tax: consolidation: can the head company of a consolidated group satisfy subsection 25-35(1) of the Income Tax Assessment Act 1997 in relation to a debt that is written off as bad by a subsidiary member, where the debt is in respect of money lent by the subsidiary in the ordinary course of its business of lending money before it became a member of the consolidated group?

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Taxation Determination TD 2005/22 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?

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Taxation Determination TD 2005/17 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?

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Taxation Determination TD 2005/15 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?

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Taxation Determination TD 2005/14 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?

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Taxation Determination TD 2005/3 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?

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Taxation Determination TD 2005/2 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?

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Taxation Determination TD 2005/1 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?

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