Tag Archives: Tax Administration Act 1953

Talking Tax – Issue 169

Foreign income tax offsets on exempt income?

The Federal Court of Australia Full Court in the case of Burton v Commissioner of Taxation [2019] FCAFC 141 rejected the taxpayer’s appeal in relation to an earlier Federal Court decision to deny the taxpayer claiming the full foreign Income Tax Offset (FITO) available under section 770-10 of the Income Tax Assessment Act 1997 (Cth) (ITAA 1997).

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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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