Category Archives: Part IVA

Unfortunate facts for those who want more tax from multinationals

Posted on April 27, 2015 by

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 … Continue reading →

Posted in Income Tax, Part IVA, Tax Policy | Leave a comment

Partnerships of Discretionary Trusts on the nose…

Posted on September 1, 2014 by

Late last year the Commissioner released a Taxpayer Alert on the use of partnerships of discretionary trust by professional practices to avoid tax. In the Taxpayer Alert late last year the Commissioner stated that he was concerned that the dominant … Continue reading →

Posted in Income Tax, Part IVA, Planning Idea, Planning Stuff | Leave a comment

Employee Benefit Trusts And “Deep Throat”

Posted on March 8, 2014 by

Many years ago I received a call from a very junior ABC journalist (her career has very much blossomed since the and she is now a household name). We met in a meeting room where I worked an she provided … Continue reading →

Posted in FBT, Income Tax, Part IVA, Planning Idea, Planning Stuff | Leave a comment

Part IVA and partnerships of discretionary trusts

Posted on November 30, 2013 by

The most annoying habit of the Commissioner is to let everyone do something for years and then to finally try to close it down. Take the Commissioner’s announcement on 16 December 2009 that an unpaid present entitlement from a trust … Continue reading →

Posted in Income Tax, Part IVA, Planning Stuff, Rulings | Tagged , , , | Leave a comment

Part IVA applies to small businesses

Posted on November 29, 2013 by

I don’t get that so many small business advisors think Part IVA can not apply to their clients. Yes it does not happen often but if it does your business is on the line. And here is where it is … Continue reading →

Posted in Income Tax, Part IVA, Planning Stuff | Tagged , , | Leave a comment