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Income Tax Part IVA Tax Policy

Unfortunate facts for those who want more tax from multinationals

I once worked for one of these multinationals. It was a US Company with a direct investment in Australia. The US company charged the Australian subsidiary management fees for head office costs, legal, finance… We were subject to a transfer pricing review by the ATO and at the same time the IRS in the US subjected […]

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Income Tax Rulings

The Commissioner believes in drinking in moderation?

In Taxation Determination TD 2015/9 the Commissioner provides amounts that he will accept as estimates of the value of goods taken from trading stock for private use by taxpayers in named industries. This helps certain businesses estimate what trading stock has been “sold” outside the normal course of business (like eaten by the owners). So if you […]

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Planning Idea Super

Superphobia…

Do you have clients who want their money now? “I wont live long enough to get my super!” They want the whole 100% in their hand, not just 91.53% ($91.53 + (9.25% of $91.53) = $100)… Well maybe you can legally help them… In ATO interpretative decision ATOID 2015/9 the Commissioner considers whether there are SG obligations […]

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Legislation Rulings

Earnouts – the wait is over

A long, long time ago in a Tax Office far, far away… After waiting 6 and a half years the Treasury has finally drafted some legislation to fix up how capital gains tax concessions apply to earnouts. But just a quick reminder on the history of this issue… In October 2007 the then Commissioner of […]

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Income Tax Tax Policy

How would I change negative gearing?

Simply I wouldn’t.  But having worked in an office at Parliament House and in the Federal Treasury, sometimes you have to do things you don’t agree with. And it looks like someone is going to be told yo do this  First, can we be clear there is no such part of the tax law that […]

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Super Tax Policy

Tax announcement everywhere…

I hope Chris Bowen is Prime Minister one day. Yes big call but he is measured and thoughtful and never ever in a rush. And he has now released a super tax policy. It is a good start… For those who will scream “wont we have thousands of more people on the pension if we […]

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Tax Policy

The Greens have a tax policy!!!

In the history of the Greens has there ever been a day they have made two tax announcements? Mark down 21 April. First, they have plans for small business tax. They are proposing: A 2% tax cut for small businesses Restoring and increasing the instant asset write-off threshold to $10,000 Restoring the loss carry-back provisions […]

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Income Tax Tax Policy

What is happening at the Australia Institute?

This morning the head of the Australia Institute, Richard Dennis, tells us there is no other imputation systems in the world and we can save biiillliiioonnss by removing it. Wrong and wrong… But exactly what Fairfax journalist would love to print so he is a very good lobbyist. First, I assume he has never heard […]

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Tax Policy

I give up… Media and tax reform

To the Fairfax and ABC media screaming that corporates dont pay enough tax, here is a lesson that is pitched for those with limited desire to investigate – i.e. Journalists. Bill Pty Ltd runs a petrol station. He buys 2 million litres of fuel each year. He buys it at $1.50 and sells it at […]

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Tax Policy

Swings and tax roundabouts…

“Google should pay more tax in Australia. If their customers are in Australia, that is where they should pay tax…” So I was told today. My response… One of Australia’s biggest tax payer, Rio Tinto, sells 35% of its products to China but pays all its tax (almost all) in Australia. If you believe in […]