Published on 02 Feb 07
by THE TAX INSTITUTE
Joint professional body submission in relation to the draft consolidation taxation determination TD 20006/D46. Income tax: consolidation: in applying the statutory cap in section 705-40 (tax cost setting amount for reset cost base assets held on revenue account) of the Inocme Tax Assessment Act 1997, does the definition of revenue asset in section 977-50 of that Act include any CGT asset, a hypothetical realisation of which would have an amount reflected in the joining entity's taxable income (disregarding the single entity rule), othewise that solely as a capital gain or capital loss?
NATIONAL INSTITUTE OF ACCOUNTANTS
TAXPAYERS ASSOCIATION OF NEW SOUTH WALES
TAXATION INSTITUTE OF AUSTRALIA