Taxation in Australia

The Taxation in Australia Journal

Written by practitioners for practitioners Taxation in Australia® is continually ranked as Australia's leading tax journal. Access the latest issue of Taxation in Australia in print, on your iPad or Android tablet, or online with our new digital edition.

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With a readership exceeding 35,000, Taxation in Australia is published 11 times per year and available exclusively to members in hard copy and online format, and now as an app on the Apple iPad and on Android tablets. This comprehensive publication features articles with a strong, practical approach to the latest tax issues and professional development. It is affectionately known as the Blue Journal.

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Articles from the current issue:

  • Forgive but don’t forget: CGT event C2 and related party loans Add to cart

    01 Sep 2015

    When loans between related parties are forgiven, particularly within family groups, it is important that the tax issues that may arise are not forgotten. Such issues may include determining if and when CGT event C2 happens under Subdiv 104-C of the Income Tax Assessment Act 1997 (Cth) (ITAA97), and considering the consequences of the personal-use asset provisions of Subdiv 108-C and the market value substitution rules in Subdiv 112-A and Div 116 ITAA97.

    This article provides guidance on the tax issues that may arise when CGT event C2 happens to a related party loan as a consequence of forgiveness and a capital loss is intended to be claimed, or carried forward, by the lender.

  • After-tax investing for superannuation funds: What should managers manage? Add to cart

    01 Sep 2015

    The transition from a pre-tax investment focus to a genuine after-tax investment focus is an important trend shaping the way large funds manage their investment portfolios. This creates opportunities for tax professionals to use their knowledge and skills to help superannuation funds deliver on their core mission, generating healthy investment returns for members. This article identifies some misunderstandings around the types of investment taxes funds are seeking to address as part of their investment strategy, and provides a model for understanding how these taxes can be effectively managed.

    The article focuses in particular on the impact of capital gains tax on a large fund’s listed equities portfolio, which represents an average 46% of the fund’s invested capital. The article concludes by describing an emerging investment approach known as “centralised portfolio management”, which demonstrates how these insights can be implemented in an intelligent, methodical and practical way.

  • Part IVA and consolidated groups: Grazing on uncertainty Add to cart

    01 Sep 2015

    The decision of the Full Court of the Federal Court in Channel Pastoral Holdings Pty Ltd v FCT was the second of two decisions which have considered the interaction of Pt IVA (the general anti-avoidance provision) of the Income Tax Assessment Act 1936 and the tax consolidation regime (the first was FCT v Macquarie Bank Ltd). In Channel Pastoral, the court held that Pt IVA could apply to a scheme or an arrangement involving the formation of a tax consolidated group, and that the correct entity to which to issue a determination and corresponding assessment (or amended assessment) is the group member which would have derived the tax benefit had the consolidated group not been formed.

    This article examines the case in detail, outlines a number of implications, and argues that there is still confusion as to who should be the subject of a determination and an assessment in these situations.