Hybrid Mismatch Rules The hybrid mismatch rules are broadly designed to prevent taxpayers from exploiting differences in the operation of the tax laws of 2 or more countries by way of a...
Hybrid Mismatch Rules
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Tax Articles
Unpaid Present Entitlement (UPE)
Unpaid Present Entitlement (UPE) What is present entitlement? The term present entitlement broadly refers to the right of a beneficiary to a share of trust income. The present...
Bad Debt
Bad Debt What is a Bad Debt?A bad debt refers to money owed to a person from a customer or debtor that cannot be recovered. The meanings of bad and debt are worth addressing in further detail...
Private Ruling
Private Ruling A private ruling is written advice from the Australian Taxation Office (ATO) about the way taxation law may apply to a particular taxpayer arrangement (a scheme), including a...
Part IVA
Part IVA What is Part IVA? Part IVA of the Income Tax Assessment Act of 1936 contains the income tax general anti-avoidance rule (GAAR). The GAAR operates alongside a number of other specific...
Debt and Equity Rules
Debt and Equity Rules There are broadly two major categories of funding available to a business: debt funding and equity funding. From a basic legal point of view and in the context of...
Everett Assignment
Everett Assignment What is an assignment?An assignment involves an entity or individual (the assignor) transferring contractual rights and benefits to another entity or individual (the...
Business Commencement & Closure Deductions
Business Commencement & Closure Deductions The most common way a taxpayer will be eligible for a deduction on business related expenditure is by satisfying the criteria of section 8-1 of the...
Taxable Australian Property
Taxable Australian Property A foreign resident of Australia for tax purposes is generally only subject to Australian tax on Australian sourced income. However, when it comes to capital gains...
