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One of the fundamental proposals recommended by the Review of Business Taxation, and accepted in principle by the Government, is the adoption of a cashflow/tax value approach to the calculation of taxable income - Option 2. This paper discusses the proposed cashflow/tax value approach, and outlines the present status of the proposal.
The purpose of this paper is to evaluate the impact of the Ralph Review and subsequent Government announcements and legislation on the CGT regime. The paper does this in the light of the Government's responses to the Ralph recommendations contained in the Treasurer's Press Releases dated 21 September 1999 and 11 November 1999.
When the Government announced in August 1998 its plan to reform the tax treatment of business entities as part of an overall tax reform plan for a new tax system, it foreshadowed the choice for groups of entities to be taxed as a single entity. This paper reviews the proposed new consolidated system, and refers to the current provisions containing concessions and anti-avoidance rules for transactions within company groups.
Mark L ROBERTSON
The proposal that entities which offer their ultimate proprietors some limit on liabilities should be taxed in a manner akin to the taxation of companies and limited partnerships, suggested in the Ralph Review, was endorsed by the Federal Government in both its Stage 1 and Stage 2 responses to the Ralph recommendations. This paper examines the background of the entity taxation system proposals, outlines the key concepts underlying consistent entity taxation - and how they relate to one another - and defines some of the terminology that relates to entity taxation.
A summary of the major recommendations of the Ralph Review pertaining to tax losses, including references to the relevant section of the July 1999 report "A Tax System Redesigned", are detailed in this paper.
The "profits first" rule had its genesis in two unrelated policy developments. The first was the abolition of the requirement of maintenance ofcapital in the Corporations Law. The second was the decision of the government to establish a common regime of taxation of all entities, which meant that entities which had never had such rules as part of their own structure (and in particular trusts) had to be fitted within a common framework. This paper examines the analysis of the entity taxation system set out in A Platform for Consultation, the 2nd Discussion Paper of the Ralph Review of Business Taxation.
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