Published on 15 Oct 04
by SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE
The following are issues for all practitioners - we can all learn from each other as we explore:
- interest and the use to which the borrowings are put
- interest incurred before income
- interest incurred after income
- capital protection premiums and Firth's Case and the way the law was changed and what it says now
- split loans and compound interest - the real issues in Hart's Case?
- was the ATO 'interested' in Hart's Case or was it only Part IVA?
- more recent ATO activity No Doc Loans - is it only about default assessment for undeclared income or is this a new 'Firth' issue stirring?
Patrick C GALLAGHER
Patrick is a Taxation and Business Consultant and a Visiting Fellow at Macquarie University. He was previously Associate Professor in the School of Law at the University of Western Sydney. Before moving to UWS Patrick was with UNSW where he was one of the two people who conceived and created the Australian Taxation Studies program. At ATAX and since, Patrick has been active as a consultant on a number of practical taxation and governance projects involving industry and/or government both in Australia and overseas - in particular, China. He also possesses undergraduate degrees in accounting and law and Masters degrees in Law and Commerce. He is a Fellow of the Tax Institute and an active member of the NSW Education Committee.
Current at 26 June 2006
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