Draft ruling on interest deductibility: an exercise in damage control

Dabner, Justin (2000) Draft ruling on interest deductibility: an exercise in damage control. CCH Tax Week, 04 May 2000 (18). pp. 1-4.

[img] PDF (Published Version) - Published Version
Restricted to Repository staff only

View at Publisher Website: http://prod.resource.wkasiapacific.com/r...


[Extract] Draft Taxation Ruling TR 2000/D3 (which deals with interest deductibility) is a cynical response by the Tax Office to its losses in the High Court in Steele v FC of T 99 ATC 4242 and the Full Federal Court in FC of T v Brown 99 ATC 4600. The Tax Office has demonstrated considerable linguistic dexterity in interpreting those judgments in such a way as to identify limitations on what were, essentially, complete victories for the taxpayers.

The issue in Steele was the availability of an interest deduction prior to the generation of income. Brown dealt with the continuing availability of a deduction for interest upon the cessation of income-producing activities. Each case and the Tax Office's response is considered below.

Item ID: 33814
Item Type: Article (Commentary)
ISSN: 1320-9426
Date Deposited: 05 Feb 2017 23:09
FoR Codes: 18 LAW AND LEGAL STUDIES > 1801 Law > 180125 Taxation Law @ 100%
SEO Codes: 97 EXPANDING KNOWLEDGE > 970118 Expanding Knowledge in Law and Legal Studies @ 100%
Downloads: Total: 1
More Statistics

Actions (Repository Staff Only)

Item Control Page Item Control Page