Published on 15 Feb 00
by QUEENSLAND DIVISION, THE TAX INSTITUTE
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.
David is admitted to practice in New South Wales, Queensland, Victoria, the Northern Territory, the Australian Capital Territory, New Zealand, Papua New Guinea and the Courts of Dubai International
Financial Centre. He was first appointed Queen’s Counsel in 1986 and holds that office in all the above Australian jurisdictions. He currently practices in Sydney (Ground Floor Wentworth Chambers) and Brisbane (Sir Harry Gibbs Chambers) with a principal focus on revenue law generally. He has acted for Commonwealth and State Governments as well as individuals and corporations. He has had a long connection with the Taxation Institute of Australia including being its President from 1993 to 1995 and President of the Asia Oceania Tax Consultants Association from 1996 to 2000.
Current at 17 May 2008
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