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Model litigant rules
- Piper Alderman
- -
- Australia
- -
- May 24 2013
The Australian Taxation Office is subject to Model Litigant Policy under Legal Services Directions made by the Attorney-General. In a recent case a
Limited partnership USA double tax agreement
- Piper Alderman
- -
- Australia, USA
- -
- May 24 2013
In broad terms, non-residents are required to include in the calculation of their net capital gains, any capital gains or capital losses made with
Sham loans taxpayer wins appeal
- Piper Alderman
- -
- Australia
- -
- April 2 2013
In a recent case, the Full Court had to consider whether or not a finding by the AAT that international funds transfers made as between the taxpayer
Scheme promoter civil penalty provisions commissioner loses
- Piper Alderman
- -
- Australia
- -
- April 2 2013
The Federal Court recently had to consider the application of the scheme promoter penalty regime introduced by the Government in 2006 for the purpose
Small business CGT relief - maximum net asset test - liabilities related to an asset
- Piper Alderman
- -
- Australia
- -
- April 2 2013
Once again the complexity of the small business CGT concessions has been revealed in a recent Full Federal Court decision and shows the importance in
Non-portfolio dividend trust as the head company of consolidated group
- Piper Alderman
- -
- Australia
- -
- January 20 2013
Under the tax consolidation provisions, a trust (as distinct from the trustee) which is a corporate unit trust or a public trading trust can be a
Litigation funding scheme is not a financial product
- Piper Alderman
- -
- Australia
- -
- November 8 2012
The NSW Court of Appeal by a majority had previously held that a funding agreement in relation to a litigation funding arrangement was a financial product
Fiduciary duties of financial advisors
- Piper Alderman
- -
- Australia
- -
- November 8 2012
Although it is hard to understand how this view could have arisen, there was a view amongst some members of the financial planning industry that financial planners did not owe fiduciary duties to their clients
GST general anti-avoidance provision
- Piper Alderman
- -
- Australia
- -
- August 29 2012
The Full Court of the Federal Court recently had to consider the application of the general anti-avoidance provisions as well as the application of the margin scheme
Deductibility of indemnity payment
- Piper Alderman
- -
- Australia
- -
- August 29 2012
The Full Court has recently held that a payment made by the taxpayer to a related company for indemnifying the taxpayer company against loss under an anterior forward exchange contract with another related company was an allowable deduction under the general deduction section
