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20 May 13 High Court refuses special leave in Sent

The High Court (Kiefel and Keane JJ) has refused the taxpayer special leave to appeal from the decision of the Full Federal Court in Sent v FCT [2012] FCAFC 187 (19 December 2012).

In that case, the Full Federal Court held that a payment to an executive share trust on behalf of the taxpayer, the managing director of a public company, in connection with the cancellation of his bonus entitlements (accrued, accruing and yet to accrue) was ordinary income and wholly assessable to the taxpayer.

The High Court said: "The judgments apply settled principles and we see no reason to doubt the conclusion reached. Special leave is refused with costs."

Sent v FCT [2013] HCATrans 108 (10 May 2013)


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