Important: Reset your password We've made some changes to our website. You will need to reset your password to access your account, access online books, purchase items from our online shop, or download papers from the Tax Knowledge eXchange.
Published on 24 May 07
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
Section 51 has been one of the most litigated provisions of our tax legislation. In 1997 it was replaced by section 8-1. This paper covers how these provisions been interpreted and applied by the ATO and by the Courts since 1997 including consideration of:
general deductability - what has happened since 1997?
demarcation or boundary issues with the remainder of the legislation
timing of deductability issues
purpose and when it becomes relevant
how does all this fit with the consolidation regime?
Mark specialises in tax law with Clayton Utz. Working with mergers and acquisition specialists, he provides advice on tax structuring for business combinations. In this context, Mark advises on issues such as scrip for scrip relief, demergers, and the new tax consolidation rules. He has a detailed knowledge of the taxation of financial instruments and transactions, corporate tax, trust taxation, capital gains tax, treaties and consideration of reform of business tax issues. Current at 11 April 2007
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
We've made some changes to our website. You will need to reset your password to access your account, access online books, purchase items from our online shop, or download papers from the Tax Knowledge eXchange.
To reset your password, click on 'Reset password' below.