TAA 1953 s IVAAA

Income tax: consolidation: does the continuing majority-owned entity test in subsections 701A-1(1) and 701A-1(2) of the Income Tax (Transitional Provisions) Act 1997 require tracing through interposed entities to the ultimate beneficial owners to determine whether there has been a change in the majority ownership of an entity during the period from 27 June 2002 until the entity becomes a subsidiary member of a consolidated group?

Income tax: consolidation: for the condition outlined in subsection 707-328(4) of the Income Tax (Transitional Provisions) Act 1997 , are Subdivisions 170-A and 170-B of the Income Tax Assessment Act 1997 applied as if they had not been amended, by Schedule 3 to New Business Tax System (Consolidation) Act (No. 1) 2002 , to only provide for loss transfers involving an Australian branch of a foreign bank?

Income tax: consolidation: is there any apportionment under section 707-335 of the Income Tax Assessment Act 1997 to the limits calculated under subsection 707-350(3) of the Income Tax (Transitional Provisions) Act 1997 regarding the utilisation of losses?

Income tax: what amount of deduction is available under section 40-25 of the Income Tax Assessment Act 1997 for the decline in value of copyright in patient records in respect of arrangements similar to those described in Taxpayer Alert 2004/5?

Income tax: consolidation: life insurance: do sections 705-75 and 705-80 of the Income Tax Assessment Act 1997 apply to a policy liability that has been valued under section 713-520 for the purposes of working out step 2 of the allocable cost amount, for a joining entity that is a life insurance company?

Income tax: does a resident of a country with which Australia has a Tax Treaty, have a permanent establishment solely from the sale of trading stock through an internet website hosted by an Australian resident internet service provider?

Income tax: consolidation: is Australian currency, where it is taken to be foreign currency under section 960-80 of the Income Tax Assessment Act 1997 for the purposes of the functional currency provisions, treated as a retained cost base asset under the consolidation regime?

Income tax: consolidation: can the head company of a consolidated group satisfy subsection 25-35(1) of the Income Tax Assessment Act 1997 in relation to a debt that is written off as bad by a subsidiary member, where the debt is in respect of money lent by the subsidiary in the ordinary course of its business of lending money before it became a member of the consolidated group?

Income tax: consolidation: is an adjustment under section 705-160 of the Income Tax Assessment Act 1997 required where the relevant membership interests are in a chosen transitional entity with losses?

Income tax: consolidation: if a transitional group has a non-chosen subsidiary in which all membership interests of the head company are held indirectly through a chosen transitional entity, and the non-chosen subsidiary has accrued profits, can an adjustment arise under section 705-160 of the Income Tax Assessment Act 1997 when working out the head company adjusted allocable amount under section 701-20 of the Income Tax (Transitional Provisions) Act 1997 for another non-chosen subsidiary?

Income tax: does a taxpayer in a passive investment have day to day control over the operation of an agreement for the purposes of paragraph 82KZME(3)(b) of the Income Tax Assessment Act 1936?

Income tax: is the income of a property syndicate taxable as net income of a trust estate under Division 6 of Part III of the Income Tax Assessment Act 1936 where the syndicate is a registered managed investment scheme under the Corporations Act 2001 and the responsible entity holds the income producing property of the syndicate for scheme members as scheme property?

Income tax: will Part IVA of the Income Tax Assessment Act 1936 always apply if a taxpayer who carries on a business (including a personal services business) pays superannuation contributions that do not exceed the age-based limits but are considerably in excess of the value of the services provided by the employee?

Income tax: consolidation: will a choice to consolidate under Part 3-90 of the Income Tax Assessment Act 1997 affect the method of income recognition of the consolidated group?

Income tax: does expenditure - which is a non-capital cost of ownership of a CGT asset - form part of the cost base of the asset, if it is a tax benefit in connection with a scheme to which the general anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936 apply?

Income tax: what are the results for income tax purposes of entering into a profit washing arrangement as described in Taxpayer Alert TA 2005/1?

Income tax: must an outgoing incurred by a supplier in deriving income from a taxable supply be apportioned when calculating the deduction allowable for the outgoing under section 8-1 of the Income Tax Assessment Act 1997, because some amount of the income relates to GST payable on a taxable supply, and is non-assessable non-exempt income?

Income tax: does subsection 23AG(2) of the Income Tax Assessment Act 1936 apply where a member of the Australian Defence Force is engaged in foreign service for a continuous period of at least 91 days as part of certain UN operations conducted under a UN agreement with a 'host country' which exempts from taxation in that country, the pay and emoluments received from the UN or from a participating State and on any income received from outside the host country?

Income tax: consolidation: membership: are the eligible tier-1 companies of a foreign-owned group required to form a single MEC group which includes all those eligible tier-1 companies?

Income tax: consolidation: membership: can an Australian resident company qualify as an eligible tier-1 company of a MEC group if a foreign resident entity is interposed between the Australian resident company and the top company of the group?