10 Jun 08 Land Impairment Trust Arrangement - TA 2008/11
On 6 June 2008, the ATO issued Taxpayer Alert TA 2008/11 entitled "Land Impairment Trust Arrangement". The Taxpayer Alert describes land impairment trust arrangements associated with forestry managed investment schemes (MIS). These arrangements involve the sale of land at an impaired value by a member of a group of entities that are treated as a consolidated group for income tax purposes (the group).
In a media release issued on the same day, the Commissioner, Michael D’Ascenzo, said: “We’ve advised people in the forestry industry who applied for product rulings about our concerns regarding this type of arrangement. We are particularly focusing on whether the arrangement really gives rise to a revenue or capital loss and how future distributions from the land trust should be treated for tax purposes."
For a copy of TA 2008/11, go here
For a copy of the ATO media release, No 2008/26, 6 June 2008, go here