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Aldrin DE ZILVA
This paper proposes to highlight several of the tax structuring issues confronting businesses as a result of the proposed and enacted Capital Gains Tax (CGT) reforms. There are obviously a plethora of other commercial and taxation issues that need to be considered.
Aldrin DE ZILVA
Whilst the OECD and ATO approach to date has not provided any great certainty in relation to the taxation issues associated with electronic commerce, the approach adopted currently presents a number of very interesting tax issues and planning opportunities for taxpayers. Outlined below are several of these issues and opportunities identified by the OECD and the ATO. They are - source of income, taxable presence, income characterisation, transfer pricing, consumption taxes. This is a seminar paper.
This paper provides a brief summary of the following loss and integrity measures introduced into our tax laws in recent times. These measures reflect a dramatic sharpening of the Government's focus on the role of losses in the tax system.
Since October 1998, Australian companies have raised over A$7 billion through the issue of hybrid securities in the form of trust preferred securities and income securities. This is a reflection of the active capital management strategies which have been adopted by some Australian multinational companies, particularly banks, as a means of enhancing shareholder value. The main purpose of this paper is to consider the main taxation consequences of the different types of hybrid securities which have been issued by Australian companies since October 1998. Some observations will also be made about the main focus of the ATO's review.
This paper poses a number of questions, through case studies, on direct post-CGT shares, direct post-CGT shares and loans, and on direct pre- and post-CGT shares, and then provides solutions.
Topics covered in this powerpoint presentation include: An update on the Ralph measures enacted; Recent Case Law including Brewing Investments, Ashton Mining; Contentious Tax Rulings including Interest Deductions, 100% Subsidiary.
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