Taxation Determination TD 2006/78 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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Taxation Determination TD 2006/77 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 significant individual under section 152-55 of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/76 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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Taxation Determination TD 2006/75 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 2006/74 Income tax: consolidation: membership: where a consolidatable group comes into existence at some time during a day can the head company make a choice under section 703-50 of the Income Tax Assessment Act 1997 specifying that day as the day on and after which the consolidatable group is taken to be consolidated?

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Taxation Determination TD 2006/73 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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Taxation Determination TD 2006/72 Income tax: does the relevant number determined for the purposes of working out the deductible amount of a superannuation pension or annuity under subsection 27H(2) of the Income Tax Assessment Act 1936 take into account the life expectancy of a reversionary pensioner or annuitant?

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Taxation Determination TD 2006/71 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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Taxation Determination TD 2006/68 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 328-125 of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/65 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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Taxation Determination TD 2006/63 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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Taxation Determination TD 2006/62 Income tax: are certain payments to a volunteer foster carer to provide foster care assessable income?

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Taxation Determination TD 2006/59 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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Taxation Determination TD 2006/58 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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Taxation Determination TD 2006/61 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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Taxation Determination TD 2006/57 Income tax: consolidation: what is an excluded asset under subsection 705-35(2) of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/56 Income tax: consolidation: cost setting: is a joining entity’s entitlement to claim a deduction for (or to otherwise deal with) a tax loss an asset for the purposes of section 705-35 of the Income Tax Assessment Act 1997 if: (a) the tax loss is the subject of a loss transfer agreement entered into after the joining entity became a member of the consolidated group; (b) the loss transfer takes effect prior to that time; and (c) the joining entity is entitled to a subvention payment?

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Taxation Determination TD 2006/54 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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Taxation Determination TD 2006/53 Income tax: consolidation: exit tax cost setting rules: how is the terminating value of an asset that is treated as if it were a CGT asset under subsection 705-30(5) of the Income Tax Assessment Act 1997 worked out for the purposes of subsection 711-25(1) of that Act?

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Taxation Determination TD 2006/52 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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Taxation Determination TD 2006/51 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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Taxation Determination TD 2006/50 Income tax: consolidation: losses: when a company that joins an existing MEC group is an eligible tier-1 company, do prior group losses of the head company of that group become subject to the loss utilisation rules in Subdivision 707-C of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/49 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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Taxation Determination TD 2006/48 Income tax: consolidation: can the head company of a consolidated group claim a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest paid on funds borrowed from outside the group, where the funds were borrowed either before or after formation of the consolidated group, by it or a subsidiary member to buy shares in an existing subsidiary member from another member of the consolidated group?

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Taxation Determination TD 2006/47 Income tax: consolidation: can the head company of a multiple entry consolidated group claim a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest paid on funds borrowed after formation of the MEC group from outside the group by it or a subsidiary member to buy shares in an existing eligible tier-1 company of the group?

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Taxation Determination TD 2006/46 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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Taxation Determination TD 2006/19 Income tax: consolidation: for the purposes of working out step 1 of a consolidated group’s exit allocable cost amount in the leaving entity under section 711-25 of the Income Tax Assessment Act 1997, is the terminating value for a CGT asset determined under Division 110 for assets that have their tax cost set under subsection 701-10(4)?

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Taxation Determination TD 2006/40 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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Taxation Determination TD 2006/39 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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Taxation Determination TD 2006/38 Income tax: consolidation: can Division 711 of the Income Tax Assessment Act 1997 apply for the purpose of the core rules in Division 701 upon an entity ceasing to be a subsidiary member of an acquired consolidated group where Subdivision 705-C operates?

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Taxation Determination TD 2006/36 Income tax: consolidation: can the profit received on the disposal of membership interests in a subsidiary member of a consolidated group be income according to ordinary concepts?

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Taxation Determination TD 2006/33 Income tax: is the cost of a depreciating asset purchased by a taxpayer to assist them undertake a specific client project immediately deductible under section 8-1 or written off over the effective life of the asset under section 40-25 of the Income Tax Assessment Act 1997 if the taxpayer continues to hold the asset after the project ends?

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Taxation Determination TD 2006/32 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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Taxation Determination TD 2006/31 Income tax: is a government rebate received by a rental property owner an assessable recoupment under subsection 20-20(3) of the Income Tax Assessment Act 1997, where the owner is not carrying on a property rental business and receives the rebate for the purchase of a depreciating asset (for example an energy saving appliance) for use in the rental property

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Taxation Determination TD 2006/30 Income tax: foreign exchange: when calculating the amount of any gain or loss on disposal or redemption of a traditional security denominated in a foreign currency, should the amounts relevant to the calculation be translated (converted) into Australian dollars when each of the relevant events takes place?

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Taxation Determination TD 2006/29 Income tax: foreign currency exchange gains and losses: if a foreign exchange 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 (other than livestock that is only trading stock by reason of the statutory definition of trading stock), is that gain ‘ordinary income’ as defined in section 6-5 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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Taxation Determination TD 2006/22 Income tax: is disaster relief money received from charities, to which local, state or federal government or their agencies have made payments, assessable income of taxpayers carrying on a business?

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Taxation Determination TD 2006/28 Income tax: consolidation: capital gains: may roll-over relief under Subdivision 126-B of the Income Tax Assessment Act 1997 be available where three or more eligible tier-1 companies are restructured such that one of the eligible tier-1 companies becomes a wholly-owned subsidiary of one of the other eligible tier-1 companies and a choice to form a MEC group is made for that same day?

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Taxation Determination TD 2006/27 Income tax: consolidation: capital gains: may roll-over relief under Subdivision 126-B of the Income Tax Assessment Act 1997 be available where two eligible tier-1 companies are restructured such that one of the eligible tier-1 companies becomes a wholly-owned subsidiary of the other eligible tier-1 company that immediately before the transfer had no wholly-owned subsidiaries?

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Taxation Determination TD 2006/26 Income tax: consolidation: membership: when does a MEC group come into existence where a valid choice to form a MEC group is made under section 719-50 of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/25 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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Taxation Determination TD 2006/21 Income tax: consolidation: imputation: which entity in a MEC group is responsible for meeting obligations imposed by Part 3-6 (the imputation provisions) of the Income Tax Assessment Act 1997 in relation to a frankable distribution made to members outside the group by an eligible tier-1 company in the group that is not the provisional head company?

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Taxation Determination TD 2006/20 Income tax: consolidation: imputation: will the benchmark rule in section 203-25 of the Income Tax Assessment Act 1997 apply in a franking period to the provisional head company of a MEC group if it is a 100% subsidiary of a foreign parent company that has more than one class of membership interest on issue?

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Taxation Determination TD 2006/18 Income tax: consolidation: when does an injection of capital, as described in paragraph 707-325(4)(a) of the Income Tax Assessment Act 1997, occur where money is received under a publicly listed share offer?

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Taxation Determination TD 2006/17 Income tax: is the deductible amount that is excluded from assessable income when a superannuation pension or annuity is paid reduced when the pension or annuity commences or finishes being paid to a taxpayer part-way through an income year?

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Taxation Determination TD 2006/16 Income tax: foreign currency gains and losses: where an amount of exempt income is paid directly into a foreign currency denominated bank account, will subsection 775-35(1) of the Income Tax Assessment Act 1997 always operate to disregard any forex realisation loss made on withdrawal of that amount?

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Taxation Determination TD 2006/12 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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Taxation Determination TD 2006/11 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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Taxation Determination TD 2006/10 Income tax: can a payment to a non-resident author for the use of his or her article be a royalty for the purposes of subsection 6(1) of the Income Tax Assessment Act 1936?

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Taxation Determination TD 2006/9 Income tax: capital gains tax: scrip for scrip roll-over: is the reference to a roll-over in paragraph 124-795(2)(a) of the Income Tax Assessment Act 1997 limited to a replacement asset roll-over listed in section 112-115 of the Income Tax Assessment Act 1997 or to a same asset roll-over listed in section 112-150 of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/8 Income tax: can a ‘small proprietary company’, not required to prepare reports under section 292 of the Corporations Act 2001, make a choice to use the ‘applicable functional currency’ under item 1 of the table in subsection 960-60(1) of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/7 Income tax: can an Australian resident company required to prepare financial reports under section 292 of the Corporations Act 2001 make a choice to use the ‘applicable functional currency’ under section 960-60 of the Income Tax Assessment Act 1997, if it is the head company of a consolidated group?

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Taxation Determination TD 2006/6 Income tax: if an ‘attributable taxpayer’ makes a choice under item 4 of the table in subsection 960-60(1) of Subdivision 960-D of the Income Tax Assessment Act 1997, to use the ‘applicable functional currency’, will this choice apply to its calculation of ‘attribution surplus’ under section 370 of Part X of the Income Tax Assessment Act 1936?

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Taxation Determination TD 2006/5 Income tax: is the ‘applicable functional currency’ choice relevant for the purpose of applying the Fringe Benefits Tax, Goods and Services Tax, Superannuation Guarantee Charge and Pay As You Go withholding provisions?

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Taxation Determination TD 2006/4 Income tax: can an Australian resident entity which keeps its ‘accounts’ predominantly in a foreign currency, choose to use that foreign currency as its ‘applicable functional currency’, where the entity is required to prepare financial statements in Australian dollars for statutory reporting purposes?

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Taxation Determination TD 2006/3 Income tax: to what extent are freight costs included in ‘qualifying Australian production expenditure’ within the meaning of section 376-40 of the Income Tax Assessment Act 1997?

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Taxation Determination TD 2006/2 Income tax: for the purposes of Division 376 of the Income Tax Assessment Act 1997, are some insurance premiums excluded from film production expenditure?

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Taxation Determination TD 2006/1 Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an ‘effectively non-contingent obligation’ to provide ‘financial benefits’ as interest payments from the time that a change in the interest rate could take effect?

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