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.
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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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