TaxRambling.com

The Rants of a Tax Nerd

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A home for tax nerds.

Hi, I’m Ken. Being a stay at home Dad to two amazing boys and one awesome wife is wonderful, but it does keep me away from my fourth love – TAX. So here I write on what is happening in tax that exits me, and hopefully it will excite you as well…

General non-arm’s length expense rules for superannuation funds

In a 2020 Practical Compliance Guidance the Commissioner indicated that a 45% tax rate could apply to all the income of a super fund – making a super fund useless from a tax perspective – if there were “non-arm’s length expenses of a general nature”. These are expenses linked to all income of the fund.…

Alienation of professional firm profits

The 2022/23 year is the first year that the Commissioner’s guidelines on the risk of Part IVA (the general anti-avoidance rule) applying to us alienating professional firm profits to lower tax entities applies – but to be honest we probably have a couple more years (see section 2.1 of the paper below). So in case…

Self education deductions and expensive MBA programmes

Below is an extract from this paper that covers this often overlooked issue… There were 11 private ruling requests in 2022 regarding whether a taxpayer could claim self-education deductions for undertaking an MBA, and that was a low year (by Jan 12 of 2023 there were already 2 for 2023).  The reason for there being…

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