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The capital/revenue distinction in financial services paper


This paper covers:

  • when is a gain on realisation of an asset ordinary income?
  • application to financial services businesses
  • impact of the consolidation rules on the analysis.

Author profile

Eugene Wheelahan QC FTI
Eugene is a barrister who practises principally in the area of tax. He has appeared in a number of leading tax cases in the High Court and Federal Court, including BHP (the “associates” case), Watson, AusNet, Orica, SPI PowerNet, Australian Pipeline Trust and Financial Synergy Holdings. He also provides opinions and assists clients in their dealings with the Commissioner. Eugene has a Master of Tax from the University of Melbourne where he is a Senior Fellow of the Law Faculty, lecturing in the subjects Comparative Tax Avoidance and Tax Avoidance and Planning. - Current at 19 June 2019
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This was presented at 2020 Financial Services Taxation Conference .

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