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Results: 1-10 of 34

No transfer of continuing partnership interest by retiring partner

  • Piper Alderman
  • -
  • Australia
  • -
  • August 27 2013

The Full Court has dismissed an appeal by a taxpayer against a decision at first instance that a deed transferring a retiring partner's interest in a

Foreign exchange losses

  • Piper Alderman
  • -
  • Australia
  • -
  • August 27 2013

The Commissioner of Taxation has lost an appeal against a decision at first instance that 20 News Corp group companies were entitled to deductions

Transfer pricing international trade

  • Piper Alderman
  • -
  • Australia
  • -
  • July 14 2010

In a recent Federal Court case, the Commissioner has suffered a significant loss in his views on transfer pricing

Time of derivation of income for cash taxpayer

  • Piper Alderman
  • -
  • Australia
  • -
  • September 20 2010

In a recent case, a taxpayer who returned income on a cash basis attempted to argue that notwithstanding he received a transfer of land in one income year as consideration for services performed in an earlier income year, that it was the value of the land at the time of performance of the services in the earlier income year that should be returned as assessable income

Scrip for scrip roll over applicability of arm’s length provisions and Part IVA

  • Piper Alderman
  • -
  • Australia
  • -
  • November 26 2010

In a recent decision of the Full Bench of the Federal Court, the Court had to consider whether or not the scrip for scrip roll over provisions applied in a takeover transaction in the context where the original entity and the replacement entity did not have at least 300 members and the shares in the replacement entity that were exchanged for shares in the original entity had different rights to the original shares

Commissioner’s slice approach to streaming of trust distributions rejected

  • Piper Alderman
  • -
  • Australia
  • -
  • November 26 2010

Up until the decision of the High Court in Bamford the Commissioner accepted that a trustee may stream categories of income to different beneficiaries e.g. capital gains and franked dividends

Youth allowance assessable income deductions allowed

  • Piper Alderman
  • -
  • Australia
  • -
  • November 26 2010

The High Court has upheld earlier decisions of the Federal Court at first instance and the Full Court on appeal that the youth allowance was assessable income

Deemed dividends - whether “distributable surplus” for an income year includes the income tax for that income year even if not due and owing

  • Piper Alderman
  • -
  • Australia
  • -
  • November 26 2010

Division 7A of the 1936 Tax Act contains specific anti-avoidance provisions that may result in a deemed dividend such as loans and other benefits provided by a private company to a shareholder or associates of a shareholder of that private company

Supply of foreign currency GST-free supply

  • Piper Alderman
  • -
  • Australia
  • -
  • November 26 2010

The High Court recently had to consider whether a sale of foreign currency on the departures side of the Customs barrier at Sydney International Airport to a traveller who intends to use the currency overseas, is GST- free

Taxation treatment of Namoi River Groundwater Structural Adjustment Program payment

  • Piper Alderman
  • -
  • Australia
  • -
  • May 27 2011

A taxpayer received a Groundwater Structural Adjustment Program (GSAP) payment from the NSW Government as part of its “Achieving Sustainable Groundwater Entitlements” Scheme which was an amount of structural adjustment assistance paid to high level users of water that was directly linked to the reductions in their access to water