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How do you determine residency as a “global citizen”?

As global employment becomes increasing fluid with individuals undertaking internal assignments, establishing the residency status of an individual becomes more complex and critical. Quy and Commissioner of Taxation [2025] ARTA 174 is a case on point that demonstrates the underlying principles of the residency tests when determining tax residency status.

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Kirtlan vs FCT: Evasion exception and Residency

The Commissioner generally has the power to amend an income tax assessment within a period of either 2 years or 4 years for other taxpayers who are not eligible for the 2-year amendment period. However, the recent case of Kirtlan and Commissioner of Taxation illustrates a rare instance where a taxpayer successfully challenged the Commissioner’s opinion that there was evasion.

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Morton’s Case and Mere Realisation

In this article we summarise the key facts and findings of the recent Federal Court decision in Morton’s Case. It provides important guidance regarding the mere realisation of a capital asset in the context of a large scale residential subdivision where land was acquired and held long term for farming before entering into a development agreement.

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Mastering Family Trusts: Navigating Family Trust Elections & Interposed Entity Elections with Confidence

With the ATO intensifying its scrutiny on FTEs and IEEs, it is imperative for tax agents to navigate these elections with precision. This article will guide tax agents through the implications of making an FTE or IEE, outline the steps to make these elections, and provide practical examples to illustrate common scenarios and strategies to avoid FTDT liabilities.

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Associates and affiliates – are they one and the same?

Navigating the complexities of tax law can be challenging, especially when it comes to understanding the nuances of related parties. Identifying which definition applies is a key step in correctly applying the law. In this article, we break down the concepts of associates and affiliates, and explain how they can impact tax outcomes.

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