Category: Part IVA
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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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Partnerships of Discretionary Trusts on the nose…
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 purpose for setting up a partnership of discretionary trusts for a professional practice was to […]
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Employee Benefit Trusts And “Deep Throat”
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 me with two private rulings – both about employee benefit trusts. The first was a […]
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Part IVA and partnerships of discretionary trusts
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 to a corporate beneficiary is a loan to which Division 7A applies. So 12 years […]
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Part IVA applies to small businesses
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 most likely to apply… You just read my post below and want to inject income […]
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