Source: Taxation In Australia Journal Article
Published Date: 1 Jun 2022
The view that tax purpose limits the extent of the "ordinary family and commercial dealing" exclusion from the meaning of "reimbursement agreement" in s 100A of the Income Tax Assessment Act 1936 is central to the views expressed in TR 2022/D1. This view is claimed to be supported by past case law. But a disciplined analysis of the exact words of s 100A in the context of the approach to statutory interpretation prescribed by the High Court, and past case law, raises serious questions over the correctness of this approach in TR 2022/D1.
Section 100A and trust reimbursement agreements - Journal 01 Jun 2023
Section 100A, Trusts and UPEs - Paper 17 May 2023
s100A panel - Video 03 May 2023
s100A panel - Audio 03 May 2023
Trust distributions in the new world order? Where are we on Section 100A podcast - Audio 02 Jul 2022
Trust distributions in the new world order? Where are we on Section 100A - Video 02 Jul 2022
Trust distributions in the new world order? Where are we on Section 100A - Presentation 02 Jun 2022
Rollovers revisited - Presentation 18 Nov 2021
Rollovers revisited - Paper 18 Nov 2021
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.