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Taxation2018-07-09T15:41:34+11:00

Proposed changes to the monster that is Division 7A

Submissions to TreasurySubmissions have now closed to Treasury concerning their Consultation Paper “Targeted Amendments to Div. 7A Integrity Rules” (October 2018– Consultation Paper).Whilst it is hoped that the submissions to Treasury may finally provide some worthwhile improvements to Div. 7A, the fact that this whole process [...]

December 6th, 2018|Taxation|

ATO response to High Court decision in Bywater

In a previous article we discussed the High Court of Australia decision in Bywater & Ors v FC of T: see http://pointonpartners.com.au/australian-tax-residence-for-companies-revisited-by-high-court-after-43-years/ Subsequent to the High Court decision, the ATO withdrew its previous ruling TR 2004/15, and issued a new draft ruling TR 2018/D3, and [...]

August 24th, 2018|Taxation|

Musings on 2018 Federal Budget

Image rights for sports people and actors It is said that the Government will “improve integrity” in the tax system by ensuring from 1 July 2019, high profile individuals are no longer able to take advantage of lower tax rates by licencing their fame or [...]

June 4th, 2018|Taxation|

Taxpayers and advisers take note: it will soon be time to pay-out UPEs or convert them to Division 7A complying loans to avoid paying deemed dividends

Background In Practice Statement 2010/4, the Commissioner set out three safe harbour investment options that taxpayers could avail themselves of to ensure an Unpaid Present Entitlement (UPE) of a company from a trust, did not attract the application of Division 7A. These options involved having [...]

September 25th, 2017|Taxation|