Skeleton Notes for Advanced Taxation Law

Description

Skeleton easy colour-coded notes to be brought into Exams that includes lecture notes, case summaries, legislative notes, textbook material. Topics included in notes: Residence and Source Introduction ¶ Residence ¶ Source ¶ Temporary residents ¶ Permanent establishments ¶ Capital Gains Tax Main residence exemption ¶ Small business concessions ¶ Australian and foreign residents ¶ Deceased estates ¶ Foreign residents capital gains withholding tax ¶ Tax Losses Introduction ¶ General tax loss rules ¶ Temporary loss carry back tax offset (2020 Federal Budget Update) Corporate loss restrictions ¶ Fringe Benefits Tax Introduction ¶ Liability to pay FBT ¶ Fringe benefits ¶ Calculating the taxable values of fringe benefits ¶ Fringe benefits taxable amount ¶ Steps involved in calculating FBT ¶ Car fringe benefits ¶ Debt waiver fringe benefits ¶ Loan fringe benefits ¶ Expense payment fringe benefits ¶ Property fringe benefits ¶ Residual fringe benefits ¶ Fringe benefits and salary packaging ¶ Companies Corporate tax rate ¶ Dividends ¶ Taxation of dividends ¶ Imputation system ¶ Franking distributions ¶ Gross-up and credit mechanism ¶ Capital returns ¶ Dividend, interest and royalty withholding tax ¶ Share buy-backs ¶ Franking credit trading schemes ¶ Partnerships Introduction ¶ Nature of a partnership ¶ Determining tax liability ¶ Partnership creation, variation and other dealings ¶ CGT and partnerships ¶ Assignments of interests in partnerships ¶ Corporate limited partnerships ¶ Trusts Introduction ¶ Nature of a trust ¶ Overview of the taxation of trust estates ¶ Meanings of key terms used in div 6 ¶ Operation of the basic rules in div 6 ¶ Revocable trusts and trusts for a settlor’s children ¶ Flow-through nature of a trust and streaming ¶ Managed investment trusts ¶ Income Alienation Anti-Avoidance Provisions Introduction ¶ Alienation of income from property ¶ Alienation of personal services income ¶ Alienation of income to minors ¶ Service entity arrangements ¶ International Taxation Introduction ¶ Dealing with international double taxation ¶ Foreign income tax offset ¶ Foreign branch income and CGT exemption ¶ Foreign equity distribution exemption ¶ CFC regime ¶ Preventing double taxation of attributed income ¶ Double Taxation Agreements Introduction ¶ Historical background to DTAs ¶ Legislative framework of Australia’s DTAs ¶ Multilateral convention ¶ Key terms used in DTAs ¶ Distributive articles in DTAs ¶ Non-discrimination article ¶ Mutual agreement procedure ¶ Exchange of information ¶ Interpretation of DTA articles ¶ Tax Avoidance Introduction ¶ Distinguishing tax avoidance from tax evasion and tax planning ¶ Judicial responses to tax avoidance ¶ Background to the general anti-avoidance provisions ¶ Core provisions in pt IVA ¶ Scheme ¶ Tax benefit ¶ Purpose ¶ Commissioner’s discretion to make a determination ¶ Restructures, Takeovers, Demergers Introduction ¶ Small business restructures ¶ Scrip for scrip takeovers ¶ Demergers ¶ Consolidation Introduction ¶ Consolidated group ¶ MEC group ¶ Core rules ¶ Cost setting rules ¶ Transfer and utilisation of losses ¶ Leaving a consolidated group ¶ Liability rules ¶