ITAA 1936 s 317

Base rate entities and base rate entity passive income

Compendium

Income tax: consolidation: are the voting interests in a foreign company held by a subsidiary member of a consolidated group treated as being voting interests of the head company of the group when determining whether section 23AJ of the Income Tax Assessment Act 1936 applies to a dividend paid to the group?

Income tax: can an Australian resident entity which keeps its 'accounts' predominantly in a foreign currency, choose to use that foreign currency as its 'applicable functional currency', where the entity is required to prepare financial statements in Australian dollars for statutory reporting purposes?

Income tax: are the active assets of a partnership, in which a foreign company is a partner, active foreign business assets of the foreign company for the purposes of the capital gains tax participation exemption provisions contained in Subdivision 768-G of the Income Tax Assessment Act 1997?

Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend when it is paid by a company (not being a Part X Australian resident) to an Australian resident company which receives it in its capacity as a partner in a partnership?

Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend paid by a company (not being a Part X Australian resident) to the trustee of a trust, even where the trustee then pays an amount attributable to the dividend to an Australian resident company beneficiary?

Income tax: whether the holding of pre-emptive rights, call options and put options constitute a contingent entitlement to acquire for controlled foreign company (CFC) purposes

First home super saver scheme

Non-Portfolio Dividends: optional convertible notes - non-assessable non-exempt income under section 23AJ of the ITAA 1936

Capital Gains Tax: disposal of goodwill by a branch to another entity

Disposal of Goodwill: tainted asset

Controlled foreign companies: amalgamation of two controlled foreign companies - transfer of assets

Controlled foreign companies: amalgamation of two controlled foreign companies - cancellation of shares

Classification of a German Kommanditgesellschaft for Australian income tax purposes

Controlled foreign companies: financial intermediary business

Classification of German Trade Tax as Federal Foreign Tax

Controlled foreign companies: financial intermediary business - foreign exchange gains on repayment or other disposal of loans

Controlled foreign companies: financial intermediary business - currency forward agreements and currency swap agreements hedging foreign currency transactions

Part IVA: multiple entry consolidated group - cancel tax benefit