Tag Archives: Income Tax Assessment Act 1936

Talking Tax – Issue 159

Forgiveness of a loan – deemed dividend under Division 7A
In VCJN and Commissioner of Taxation (Taxation) [2019] AATA 968 (23 May 2019), the Administrative Appeals Tribunal (Tribunal) agreed with the Commissioner of Taxation (Commissioner) that the taxpayer’s forgiveness of a loan should be treated as a deemed dividend per s 109E(1) of the Income Tax Assessment Act 1936 (Cth) (ITAA36).

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Talking Tax – Issue 64

ATO guidance

Taxpayer Alert 2017/1(TA 2017/1): Re-characterisation of income from trading business

The ATO are reviewing arrangements that attempt to fragment integrated trading businesses to re-characterise trading income as passive income which is favourably taxed. Where these arrangements are entered into, the general anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936 (Cth) may be triggered.

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