Published on 05 Mar 10
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers:
- proportionate v quantum approach debate
- expense allocation
- "income of the trust estate" debate
- loss recoupment
- ordinary income v trust law income
- conduit theory of streaming tax attributes debate
- reclassification of capital as income
- PSLA 2005/1 capital beneficiary approach debate
- gross or net income
- present entitlement debates.
Mark is a Queen’s Counsel with chambers in Brisbane and Sydney. He has appeared in many cases concerning the issue of purpose Australia-wide for taxpayers and for the Commissioner.
- Current at
29 November 2017