Published on 18 Apr 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
The recent McNeil decision of the High Court directly focussed attention on tax aspects associated with a range of corporate capital management strategies. In addition, there have also been a number of other important recent judicial developments of relevance to corporate distributions and shareholders. This presentation highlights the potential practical relevance of these developments including:
- Sun Alliance & Condell in the context of what constitute 'profits'
- Lend Lease addresses ownership and derivation of dividend aspects (including CGT interactions)
- Indofood International (UK) considers ownership of dividends for treaty purposes
- McNeil of course is critical in that it focuses on whether a right provided to shareholders is income.
Gordon Thring CTA
Gordon is a Partner in the Corporate Tax practice of Deloitte. He has over 20 years experience in mining and energy, financial services and property sectors. He was extensively involved in the consultation arrangements regarding the introduction of Division 125 and the amendments to s45B to accommodate demerger relief. Current at 19 March 2009
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Tim Neilson CTA
Tim is a Special Counsel of Greenwoods & Freehills Pty Limited in Melbourne.
Tim is a legal practitioner who practices primarily in the area of income tax and capital gains tax, generally for "large business and international" type clients, mainly in financing, major projects and M&A.
He is a former State Chairman of The Tax Institute, and a member of the Advisory Board for the Monash University Journal of Australian Taxation.
He has published frequently in professional journals and spoken at professional organisation conferences and seminars and guest lectures in the University of Melbourne's Masters of Laws program. Current at 01 November 2013
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