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Designed for the specialist tax professional, The Tax Specialist journal is essential reading for corporate tax advisers, accountants, lawyers and academics. Featuring in-depth analysis, opinion and argument on legislative, administrative and judicial issues it is published five times per year and is available by subscription. Also known as the Red Journal.

The Tax Specialist covers the latest issues affecting your role and your business, including:

  • consolidations
  • mergers and acquisitions
  • international tax
  • GST securitisation
  • venture capital
  • legal professional privilege
  • Part IVA
  • TOFA, and more.

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Articles from the current issue:

  • Coping with the cross-border attack: The MAAL and more

    shopping_cart Add to cart 01 Mar 2017

    Australia’s multinational anti-avoidance law (MAAL) was introduced to “counter the erosion of the Australian tax base by multinational entities”. This article explores the nature of Australia’s attack on the cross-border transactions of multinational enterprises (MNEs) under the MAAL. It explains the key relevant statutory provisions of the MAAL and where this law sits in relation to the broader international tax framework which the government has committed to shape. It explores how MNEs may be similarly impacted by the new diverted profits tax measures, which was recently introduced into parliament and will commence on 1 July 2017. It describes a field of study which can help explain how and why the ATO has announced that it is reviewing many more taxpayers than were initially described by the government as targets of the law.

  • Division 7A structuring: The contortionist revisited

    shopping_cart Add to cart 01 Mar 2017

    Under the 2016 federal Budget amendments, quarantined pre-4 December 1997 loans and pre-16 December 2009 unpaid present entitlements (UPEs) may become subject to new loan rules. In addition, 30 June 2010 subsisting UPEs on a seven-year interest-only investment agreement will require principal repayment by 30 June 2018, presenting cash-flow problems for family groups that advisers must address now. This article discusses and assesses the risks of Div 7A loans, UPE compliance management and repayment planning options, and the potential impact of proposed Div 7A reforms. The author also analyses: the intersection of Div 7A deemed dividends, Div 245 debt forgiveness, Div 974 at-call loans, and s 100A reimbursement agreements on UPEs; the impact of the Board of Taxation and 2016 federal Budget proposed reforms; strategies for the management of pre-1997 loans and UPEs and pre-2009 quarantined UPEs; and strategies for repaying and restructuring loans and UPEs so that Div 7A does not apply.

  • Voluntary disclosure options for US taxpayers with Australian assets

    shopping_cart Add to cart 01 Mar 2017

    Globalisation, multinational corporations and an increasingly mobile workforce have exposed a need for global tax transparency. Those who have had to deal with the United States tax system may be aware that this sentiment holds strongest with the US. The US foreign tax reporting laws carry severe civil and criminal penalties for non-compliance, imposing hefty fines even where a taxpayer has acted unwittingly. With the number of US taxpayers living in Australia and Australians moving to the US or establishing a US presence, the need to remain internationally tax compliant is becoming more critical. This article will explore the US foreign reporting framework against the OECD’s Common Reporting Standard, the Foreign Account Tax Compliance Act (US), the Internal Revenue Service’s tax amnesty programs and the Offshore Voluntary Disclosure Program. This article also outlines what options are available to taxpayers who are in non-compliance, either wilfully or non-wilfully.

  • AusNet and the discretionary power to reconstruct accounts: Part 2

    shopping_cart Add to cart 01 Mar 2017

    The decision of the Federal Court in the AusNet Transmission Group Pty Ltd case concerned the capital allowance treatment of copyright in various drawings and documents. The case turned on the exercise of the Commissioner’s power under s 124R(5) of the Income Tax Assessment Act 1936 to allocate a cost to the copyright assets, and vicariously on the nature and scope of the opportunities that exist for review of the Commissioner’s decision. The result of the decision is that s 124R(5) determinations are liable to objective merits review and afford no protected discretionary area to administrators. In part 1 of this two-part article, published in the October 2016 issue of the journal, the author set out the primary facts of, and issues in, the case, and discussed the decision at first instance in the Federal Court. Part 2 now turns to examine in detail the decision of the Full Court of the Federal Court on appeal, and the implications of the decision.

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