Article Abstract:
The issue of debt forgiveness in 'agency development loans', a common life insurance industry practice in the early 1990s, is examined in an analysis of the decision arrived at in Integrated Insurance Planning Pty Ltd and Michael Van Rens Financial Services Pty Ltd v FC (Federal Court of Australia, Nicholson J, 30 January 2004). The inner workings of the Melbourne City project is investigated in which Transurban sought a deduction for concession fees even before payments were made.
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Article Abstract:
The 'properly referable' provision of the Australian tax law requires that the revenue loss not only occurred but that it is also applicable in the year in which the deduction is to be taken. The deduction cannot be pre-paid. A case took place that did not deny the entire tax deduction even though it did not take place in the year of income.
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Article Abstract:
The difference between an 'election' and a 'choice' made by the tax payers as per the tax law requirements is examined. Issues relating to tax-exempt overseas income are also discussed.
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