ITAA 1997 s 855-10

Income tax: Inghams Group Limited - return of share capital

BlackWall Limited - demerger of WOTSO Limited

Qantas Airways Limited - off-market share buy-back

MetalsTech Limited - return of capital by way of in specie distribution

Incitec Pivot Limited - reduction of share capital

Income tax: does the residency assumption in subsection 95(1) of the Income Tax Assessment Act 1936 (ITAA 1936) apply for the purpose of section 855-10 of the Income Tax Assessment Act 1997 (ITAA 1997), which disregards certain capital gains of a trust which is a foreign trust for CGT purposes ?

Income tax: where an amount included in a beneficiary's assessable income under subsection 99B(1) of the Income Tax Assessment Act 1936 (ITAA 1936) had its origins in a capital gain from non-taxable Australian property of a foreign trust, can the beneficiary offset capital losses or a carry-forward net capital loss ('capital loss offset') or access the CGT discount in relation to the amount?