Tax free share buyback - but stay tuned!
27 Oct 05 |
Issue: October 2005
Pages: pp. 8-9
In the August 2004 edition of inTAX the authors examined Conti J's decision in McNeil v FCT (2004) 55 ATR 384 ("An imponderable taxing provision - or a thorn by any other name').
This month's article focuses on the decision of the Full Federal Court which was handed down on 8 August 2005 ( FCT v McNeil FCAFC 147 (to be reported in ATR)).
The authors write that this case has the potential to become the next Hepples of CGT, with the taxpayer having derived a gain which seemingly escapes both the income tax and CGT nets. Not surprisingly, the Commissioner has lodged an application for special leave to appeal to the High Court.
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Lachlan is the Global Head of Indirect Tax for KPMG, as well as leading the Indirect Tax and Tax Technology practices for KPMG China. As part of his role in KPMG China, Lachlan led KPMG China’s efforts in relation to the VAT reform pilot program in China, including providing advice to various Government agencies in relation to several key aspects of the VAT reforms, including the application of VAT to financial services, insurance, construction and real estate, transfers of a business, as well as other reforms relating to the introduction of Advance Rulings in China. Previously he was a partner of KPMG Australia for over 11 years as the head of Indirect Tax in Sydney, and the National head of Tax Controversy services for KPMG Tax Lawyers Pty Ltd. Lachlan is also formerly a Director of the Tax Institute.
- Current at
30 September 2019
Anetta is a Tax Director in the KPMG Adelaide Corporate Tax practice. She has qualifications in both law and commerce and has over 15 years' experience working as a tax advisor in various law firms and at KPMG. Prior to rejoining KPMG in December 2015, Anetta worked for 5 and a half years as a Senior Associate in the taxation group of Arnold Bloch Liebler in Melbourne where she was involved predominately in taxation audits and disputes. Anetta's work in managing and resolving audits and disputes included preparing responses to position papers, preparation and lodgement of objections to notices of assessment and penalty notices, drafting settlement proposals and ongoing communications and negotiations with the ATO. Her work at KPMG involves advising clients on general income tax and GST matters, tax and corporate restructuring, M&A transactions and taxation audits and disputes. Anetta's clients include People's Choice Credit Union, Beyond Bank, Flinders Ports and various other private groups and high net worth individuals.
- Current at
07 December 2016