The Tax Specialist
Designed for the specialist tax professional, The Tax Specialist journal is essential reading for corporate tax advisers, accountants, lawyers and academics. Featuring in-depth analysis, opinion and argument on legislative, administrative and judicial issues it is published five times per year and is available by subscription. Also known as the Red Journal.
To subscribe to The Tax Specialist please download an order form (297KB PDF).
Subscription pricing
- AUD $330 Taxation Institute Members
- AUD $385 Standard subscription
- AUD $340 Member Subscribers outside Australia
- AUD $400 Non-Member Subscribers outside Australia
Articles from the current issue:
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Superannuation funds: A beneficiary’s interest and accrued benefitsAdd to cart
This paper addresses the nature of a beneficiary’s interest in a superannuation fund and accrued benefits. The two concepts are intertwined, bound together by traditional concepts of trust and property law and the regulatory regime. An analysis of these features provides a pathway that necessarily starts with, and continues through, a legal process, potentially concluding with a calculation by an actuary (for defined benefit schemes) or by an accountant.
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What is an input-taxed supply of used residential premises?Add to cart
There has been a lack of clarity in the past about what an input-taxed supply of used residential premises is for GST purposes in Australia. A case is put forward in this article for characterising an input-taxed supply of used residential premises with reference to the planned use of the premises by the purchaser.
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Infrastructure taxation: Anti-avoidance rules and tax efficiencyAdd to cart
This article reviews the four sets of anti-tax avoidance rules that infrastructure has attracted and, also discusses the cost of the tax efficiency of deferred losses and offers some suggestions about how that efficiency can be removed.
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Going “Green”: The call to reform – the US Green BookAdd to cart
There has been a raft of proposals to reform the US international tax laws and improve their enforcement. Some of the more sensational proposals include the removal of the “check-the-box” election, the determination of deemed paid foreign tax credits on a consolidated basis for all foreign taxes paid by foreign subsidiaries and the repeal of the “80/20” corporation provisions. The impact of these changes is still unclear; however US corporations should be considering the potential impact of these changes now in the event these proposals become law.
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Section 45B: Don’t let the Commissioner lead you by the noseAdd to cart
The Commissioner says s 45B applies to all capital benefits that are attributable to profit. The text of the legislation provides scant justification for such a view. One also questions just how many capital benefits involve a tax benefit, as defined by s 45B(9).
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Safe harbour or “rule of thumb”Add to cart
The ATO is taking an expansive view of its transfer pricing powers. The release of a new draft ruling on the interaction of the thin capitalisation and transfer pricing rules has implications for all taxpayers with loans or guarantees with cross-border related parties. Taxpayers who have sought the refuge of the thin capitalisation “safe harbour” will still need to calculate a hypothetical gearing structure for a financially independent entity in the position of the taxpayer. This article explores the ATO’s position and the implications it has for non-residents funding their Australian businesses.
