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Infrastructure and property investment — some tax administration


This paper deals with some tax issues that are relevant to infrastructure and property investment by Australian listed or widely held structures. In doing this, the paper attempts to identify some practical issues, many of them matters on which there is no well-established law, policy or administrative practice. That is in the nature of practical tax administration, for practitioners and administrators alike. With listed and with widely held trusts, we are all risk averse on tax: we all inclined to avoid arrangements and actions that have significant tax uncertainty and we all prefer arrangements and actions which have more certain tax outcomes.

Author profile

Christopher Hood CTA
Chris Hood is presently a Senior Tax Counsel in the Australian Taxation Office. He has an extensive background in several areas related to trust taxation, including the operation of Divisions 6C and 6B of the Income Tax Assessment Act 1936. He worked as a member of the secretariat to the Review of Business Taxation (the Ralph Review). Before joining the ATO in 1984, and an extended career in legislative instructing work, Mr Hood was a solicitor in private practice in Sydney. - Current at 11 May 2010
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