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1. Submission on Revised Exposure Draft Tax Agents Services Bill
As reported in Edition 20/2008 of the Tax Bulletin, the revised Exposure Draft Tax Agent Services Bill and associated materials (Exposure Draft) were released for public consultation on 29 May.
The Institute has been working on a submission on this Exposure Draft which is due on 27 June. It seems to be a substantial improvement on the previous draft but there are some remaining concerns. The main concerns that we have identified so far include:
- The reasonable care requirement under the code of conduct (subsection 30-10(9) of the Bill) still seems too broad and many members have commented that it is not really an improvement from the previous draft. Our current view is that the subsection should at least be amended to give effect to the legislative intent which we understand was to limit the scope of the subsection to the engagement or contractual relationship between an agent and a client. Alternatively, the section should be removed all together and reliance should be placed on a modified subsection 30-10(7).
The Explanatory Memorandum (EM) does contain some helpful comments already, e.g., at paragraph 3.41, there is reference "to service that they have been engaged to provide". Also at paragraph 3.43, it does say that "Where there are grounds to doubt the information provided by a client". However, the EM including the examples, also require amendments to reflect the intended limitation in scope.
- In relation to the conflict of interest, subsection 30-10(5) now seems to be appropriately amended. However, the EM could be more helpful. On one reading of the EM, it could mean the end of industry specialisations which is a point we made last time. Comments need to be added to the EM to the effect that the mere fact that two clients are in the same industry of itself does not give rise to an indirect conflict of interest. The example also needs to be appropriately amended.
- In relation to outsourcing, especially the use of service trusts, the code of conduct has been appropriately amended but the problem arguably still exists because of other sections of the Bill. Consider, the interaction of section 90-5 (i.e. reference to another entity) and the reference to supervision and control in subsection 50-30. Some guidance in the EM as to the meaning of supervision and control is necessary as it could be argued that an employer/employee relationship is still necessary. The guidance could simply say that supervision and control does not necessarily require an employer/employee relationship. It could go on to say that, for example, a service entity arrangement such as those used by many accounting firms would be acceptable. Furthermore, we could add to section 6 of the Regulations services provided to a tax agent.
We have developed a detailed table of issues which contain a number of other concerns. We are continuing to work on them and it is likely that we will be lodging a joint submission with the other two accounting bodies.
We would like to thank those members that have provided comments. We now hope that the resulting legislation will address our remaining concern and that we finally have a more workable legislative framework for tax agents.
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2. TOFA Stages 3&4 – Consolidation and TOFA Interactions discussion paper released
A discussion paper on consolidation and TOFA interactions has been released by the Treasury today. In its May Budget, the Government has indicated its plan to proceed with Taxation of Financial Arrangements (TOFA) Stages 3 and 4. An important aspect of TOFA stages 3 &4 is how this measure interacts with the existing tax consolidation regime. The discussion paper which was released today proposes an approach to the interaction between the two regimes.
The Treasury calls for submissions and the due date is 11 July 2008. The Institute will be lodging a submission on this. If members have any comments they wish to be considered for inclusion in the Institute's submission, please email them to mailto:taxgroup@charteredaccountants.com.au as soon as possible.
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3. Commissioner’s speech addressed to the Committee for Economic Development
On 19 June, the Commissioner, Michael D’Ascenzo in a speech, addressed to the Committee for Economic Development in Australia said that the ATO are reinventing themselves to become more approachable and community minded. In recent years, the ATO has been a global innovator of a different model of compliance which is referred to by academics, John and Valerie Braithwaite, as the responsive regulation and taxation.
The Commissioner said that the ATO’s compliance model is based on the twin beliefs that most well informed taxpayers will respond positively to a system they believe is both fair and transparent, and act in a self regulatory manner that enables them to get on with their lives and businesses. He said that it is only a minority that pose real problems of tax evasion and avoidance. This is reflected in part by the fact that, of the $248 billion revenue collected in 2006-07, only about $5 billion were the result of active compliance activity.
The Commissioner also talked about the two facets of Annual Compliance Arrangements (ACAs) that illustrate the new compliance model.
First, ACAs recognise that tax can be a grey or ambiguous area where applied to dynamic, complex and global arrangements. However, the Commissioner said that if the ATO can demonstrate that their approach is aligned to the proper application of the law, and act fairly and professionally in workings with taxpayers, they can foster a more collaborative approach that has the potential of reducing compliance costs.
Second, ACAs will only be struck with companies which have sound corporate governance. The ATO’s underlying assumption is such companies are not only more likely to be conscious of their tax obligations but may also be more attuned to the sustainability of their market share or profits.
The Commissioner also briefly spoke about Standard Business Reporting (SBR) which is another initiative aimed at reducing the regulatory burden on businesses. He also noted that climate change with its associated emission trading system, as well as the review of the tax system are the two high priority agenda for the future.
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4. National Tax Liaison Group (NTLG) meeting
On 17 June, Ali Noroozi and Linda Wang of the Institute and Institute representative, Ann Previtera (PwC), attended the NTLG meeting in Canberra. Topics discussed at the meeting included:
- The objective and future operation of the ATO’s new consultative forum, the Large Business Advisory Group (LBAG)
- ATO funding and tax related budget issues, such as family trust elections
- Broad issues in relation to the ATO’s Test Case Funding program including its objectives and operation
- The requirement of ‘reasonable care’ as expressed in the AAT decision of Rebmik Contractors Pty Ltd v Commissioner of Taxation (2008) AATA 335
- The need for the ATO to provide guidance in relation to matters arising out of McNeil’s decision which have not been dealt with in Tax Laws Amendment (2008 Measures No.3) Bill 2008 that has been introduced into the Parliament
- Issues related to the deductibility of interest on money borrowed to invest in various classes of arrangement covered by Taxpayer Alerts, TA2008/3 and TA 2008/4
- Black hole expenditure and section 40-880 interpretative issues and,
- The Commissioner’s view on the principles enunciated in Goodman Fielder Wattie v FCT and Associated Minerals Consolidated v FCT with respect to the income tax treatment of employee related costs.
A copy of the NTLG meeting agenda that contains the ATO’s responses is here. The formal minutes of the meeting will be published on the ATO website in due course and a link provided in the Tax Bulletin.
If you have any questions in relation to the issues discussed, please email us at mailto:taxgroup@charteredaccountants.com.au.
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5. NTLG Consolidation Subcommittee meeting
On 12 June, Alexis Kokkinos (Deloitte), Tony Stolarek (E&Y) and Susan Cantamessa from the Institute attended the NTLG Consolidation Subcommittee meeting on behalf of the Institute. Matters discussed at the meeting included:
- An update of matters discussed at previous meetings, including subdivision 705-C for non-consolidated groups, trusts joining and leaving a consolidated group and straddle contracts
- Foreign hybrids
- Trade debts and potential double taxation (ATOID 2005/211) and,
- Consolidation implications of recently released draft ruling on earnouts (TR 2007/D10).
The minutes of the meeting will be published on the ATO website in due course and a link provided in the Tax Bulletin. If members would like further information, please email us at mailto:taxgroup@charteredaccountants.com.au.
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6. NTLG Losses and CGT Subcommittee meeting
On 11 June, Tony Stolarek (E&Y), Matt Hayes (KPMG) and Susan Cantamessa from the Institute attended the NTLG Losses & CGT Subcommittee meeting.
Issues included on the agenda and discussed at the meeting included:
- Company losses and the 'reasonable grounds' test in section 166-275(c)
- The impact of the decision on amended assessments of the decision in Metlife Insurance
- A number of issues in relation to the small business CGT concessions.
The minutes of the meeting will be published on the ATO website in due course and a link provided in the Tax Bulletin. If members would like further information, please email us at mailto:taxgroup@charteredaccountants.com.au.
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7. NTLG Trust Consultation Subgroup meeting
On 19 June, Brian Lane (E&Y), Alexis Kokkinos (Deloitte) and Susan Cantamessa from the Institute attended the NTLG Trust Consultation Subgroup meeting. Topics discussed at the meeting included:
- Trust cloning and trust splitting
- The proposed decision impact statement on the High Court's decision in Raftland's case
- Recent cases, namely, ConnectEast Management Ltd, Bamford and Ryan and,
- Issues stemming from the Cajkusic Decision Impact Statement.
The minutes of the meeting will be published on the ATO website in due course and a link provided in the Tax Bulletin. If members would like further information, please email us at mailto:taxgroup@charteredaccountants.com.au.
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8. NTLG Finance & Investment Sub-group meeting
On 16 June, Alexis Kokkinos (Deloitte), Gavin Marjoram (PwC) and Adam Gibbs (KPMG) attended the NTLG F&I Sub-group meeting on behalf of the Institute. Key matters arising out of the meeting includes:
- Two taxation determinations on deferred purchase arrangements (DPA) are to be finalised after year end. The DPA draft determination on the CGT interactions has gone before the rulings panel.
- In relation to the outstanding item on total return swaps (TRS), the ATO noted that it may be difficult for a TRS to qualify as a Division 6C eligible instrument. However, the ATO qualified this statement by stating that it would depend on the swap arrangement.
- The term “obligation” for the purpose of section 974-135 has been accepted on the rulings program, and a draft TD has been prepared. The draft determination is to be issued in October 2008.
- The ATO had prepared a paper on the derivation issues related to short sale transactions in ATOIDs, 2007/197 and 2007/198. The ATO stated that they would consider their draft internal paper soon and would let the members know of their interim thinking, hopefully before 30 June 2008..
- Examples on Division 250 have been drafted and the ATO is in the process of finalising them and release as fact sheets.
- Treasury provided an update on TOFA 3&4 and indicated that they were still working on the provisions and that they anticipated releasing an interaction paper for tax consolidation over the next week for consultation.
- On section 974-80, the ATO stated that they still maintained their views in their withdrawn discussion paper. Although they were not contemplating actively reviewing such arrangements, they maintained that they would uphold their view if a taxpayer applied for a ruling or if a taxpayer was under review. Treasury stated that they were working on an amendment, however the provision had not been given Government approval and was ranked as a lower priority issue for Treasury.
- There was a discussion of section 974-135 and limited recourse debt arrangements. The ATO were also interested in examples and agreements relating to limited recourse debt arrangements, in order to help progress a view as to how section 974-135 applies to such arrangements.
- An update was provided on the proposed managed funds TD on the revenue versus capital distinction of holding certain assets. A draft determination is expected to be released soon on the issue. The TD had been before the rulings panel.
A copy of the NTLG F&I Sub-group meeting agenda is here. The formal minutes of the meeting will be published on the ATO website in due course and a link provided in the Tax Bulletin.
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9. Joint submission on draft Taxation Ruling
The Institute has lodged a joint submission, available on the Institute website, on the following draft Taxation Ruling.
TR 2008/D4 - Petroleum resource rent tax: application of Petroleum Resource Rent Tax Assessment Regulations 2005 to an integrated gas-to-liquid operation.
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10. No scope to set aside objection decision because of lengthy period of time elapsing - Dunn v Commissioner of Taxation [2008] AATA 503
The Tribunal has affirmed the decision of the Commissioner, stating that it only had jurisdiction to set aside the objection decision where the applicant had discharged the onus of establishing that the assessment was excessive pursuant to section 14ZZK(b) of the Taxation Administration Act 1953, which he had not done.
The Commissioner issued an amended assessment in June 1999 to the applicant in respect of the year ended 30 June 1994, which the taxpayer lodged an objection to in July 1999, claiming it was excessive. The respondent disallowed the objection in full some 5 years later. The applicant contended that the respondent had “an implied statutory duty” to make his decision on the objection within 12 months.
In rejecting this contention, the Tribunal concluded that ‘… there is no scope for the Tribunal to set aside the objection decision because a lengthy period has elapsed between the time the objection against the assessment was lodged and the time the objection decision was made, regardless of the length of that period.’ (at para 37)
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11. Delay in respondent making objection decision, no ground to set aside assessment decision - Bankstream Pty Ltd v Commissioner of Taxation [2008] AATA 504
The Tribunal has affirmed the decision under review in this matter finding that delays in the respondent making the objection decision did not provide grounds to set aside the assessment decision. In reaching this view, the Tribunal adopted its findings in the decision above, as the issues arising were the same.
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12. Appeal update
The taxpayer has appealed to the Full Federal Court after the single judge upheld the decision of the Tribunal and the Tax Agents’ Board of NSW to refuse re-registration of the tax agent in Shaheed v Tax Agents’ Board of New South Wales [2008] FCA 703 on the basis of not being a ‘fit and proper person’, as reported in Edition 20/2008 of the Tax Bulletin.
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13. Draft Taxation Determination
TD 2008/D8 - Income tax: when is income tax of a private company a 'present legal obligation' for the purposes of the distributable surplus calculation under subsection 109Y(2) of Division 7A of Part III of the Income Tax Assessment Act 1936?
The Institute will be preparing or co-ordinating the preparation of submissions to the ATO in respect of these Draft Taxation Determinations. If you have any comments please e-mail them to us at mailto:taxgroup@charteredaccountants.com.au by 8 July 2008.
Withdrawal
TD 2007/D9W - Withdrawal - Income tax: is income tax of a private company properly payable for an income year, but unpaid at the end of that year, a 'present legal obligation' for the purposes of the distributable surplus calculation under subsection 109Y(2) of Division 7A of Part III of the Income Tax Assessment Act 1936?
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14. Goods and Services Tax Ruling - Addendum
GSTR 2002/3A2 - Addendum - Goods and services tax: prizes
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15. Product Rulings
PR 2008/57 - Income tax: tax consequences of investing in the Retirement Booster - Prospectus 1
PR 2008/58 - Income tax: tax consequences of investing in MQ Listed Protected Loan
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16. PAYG Variation and Notice
Notice 25 - Notice exempting entities from giving a payment summary for lump sum superannuation benefits to certain recipients with a terminal medical condition. Signed on the 30th day of May 2008
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17. ATO Interpretative Decisions
ATO ID 2008/91 - Income tax: deductibility of expenditure on cables and cable support equipment by a service provider
ATO ID 2008/92 - Capital Allowances: balancing adjustment event where a service provider gives up cable and cable support equipment to another entity
ATO ID 2008/93 - Capital Allowances: cost of depreciating asset - instalment costs
ATO ID 2008/94 - GST and changes in net amount outside the four year time limit
ATO ID 2008/95 - Excess contributions tax: notional taxed contributions - new entrant age
Withdrawn Interpretative Decisions
ATO ID 2003/685 (Withdrawn) - Foreign tax credit on UK dividends paid by UK resident company to an Australian resident individual taxpayer
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18. House of Representatives’ draft legislation program for 23- 26 June
The House of Representatives has released its Draft Legislation Programme Winter Sittings for the period 23 to 26 June. It is expected to resume debate on Tax Laws Amendment (2008 Measures No.2) on 23 June.
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19. Senate’s revised draft legislation program for 23 - 26 June
The Senate has released its Revised Draft Legislation Program for the period 23 to 26 June. It is expected to resume debate on Tax Laws Amendment (2008 Measures No. 1) Bill 2008 on 24 June.
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20. Tax Bills referred to Senate Committees
The following tax-related Bills have been referred to Senate Committees on 18 June:
- Tax Laws Amendment (Medicare Levy Surcharge Thresholds) Bill 2008
- Tax Laws Amendment (Luxury Car Tax) Bill 2008
- Excise Legislation Amendment (Condensate) Bill 2008
- Tax Laws Amendment (2008 Measures No.3) Bill 2008
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21. Tax Bills passed by the Senate
The following tax-related Bills have passed by the Senate without amendment and now await Royal Assent:
- Tax Laws Amendment (Personal Income Tax Reduction) Bill 2008
- Tax Laws Amendment (Medicare Levy and Medicare Levy Surcharge)Bill 2008
- First Home Saver Accounts Bill 2008, Income Tax (First Home Saver Accounts Misuse Tax) Bill 2008 and First Home Saver Accounts (Consequential Amendments) Bill 2008
- Tax Laws Amendment (Election Commitments No 1) Bill 2008, Income Tax (Management Investment Trust Withholding Tax) Bill 2008 and Income Tax (Managed Investment Trust Transitional) Bill 2008
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22. Tax Laws Amendment (2008 Measures No 2) Bill 2008 passed by the Senate with amendments
Tax Laws Amendment (2008 Measures No. 2) Bill 2008 was passed by the Senate on 17 June with amendments. The amendments insert two new schedules into the Bill relating to the income tax treatment of rent assistance paid to Austudy recipients and the Carer Adjustment Payment. These were previously contained in Tax Laws Amendment (2008 Measure No.3) Bill 2008.
Tax Laws Amendment (2008 Measures No. 2) Bill 2008 with amendments will now go back to the House for consideration.
The amendments and Supplementary Explanatory Memorandum are available here.
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23. Legislation cleared for introduction
Amendments to Tax Laws Amendment (2008 Measures No 2) Bill was cleared for introduction into the Parliament on 17 June.
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24. Legislative Instrument
The Income Tax (Effective Life of Depreciating Assets) Amendment Determination 2008 was registered on the Federal Register on 23 June 2008.
The instrument provides taxpayers in specific industries and for specific assets with effective lives as a basis to calculate the decline in value (depreciation) of an asset for income tax purposes.
This Determination commences on 1 July 2008.
View the Explanatory Statement.
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25. Recent ATO publications
Booklets and publications
Changes to reporting of contraventions - Changes to reporting compliance audits of self-managed funds for approved auditors and actuaries from 1st July 2008. The new approved form must be used, it is event based, new tests have been introduced to help auditors follow the reporting criteria. How to obtain and lodge an ACR, acess to information after lodgment. Amending and updating lodged ACRs.
Non-business boating activities: overview - fact sheet - Information for taxpayers who derive income from their boats. Deductions can be claimed to the extent that deductions are incurred from boating activities even though you can not demonstrate that you are carrying on a boating business. Note, TR2003/4 will be updated to include an addendum, reflecting legislative amendments and their application.
Demutualisation of MBF - This information applies to you if you had a private health insurance policy with MBF on 8 November 2007 and receive a payment of cash under the demutualisation of MBF which is proposed to take place on 16 June 2008.
eLink 21/08 - Bulletin to inform tax practitioners of the most recent updates to ato.gov.au including a lead article titled 'We can help you update your client list'. Issued 4 June 2008.
Luxury car tax: increase in luxury car tax rate - The Government announced in the 2008-09 Budget that it will increase the luxury car tax from 25 per cent to 33 per cent from 1 July 2008.
Administration
Portal maintenance schedule - Scheduled downtime for 2008.
Last chance to fix certain tax mistakes without penalty - Time is running out for people to take advantage of a one-off opportunity to correct past tax mistakes for payments and loans from private companies without facing penalties or interest.
FEE-HELP and tax deductibility - Provides students information regarding entitlements to a tax deduction for some of the costs associated with taking an FEE-HELP loan to pay their tuition fees.
OS-HELP and tax deductibility - Provides students information regarding entitlements to a tax deduction for some of the costs associated with overseas study.
Lost members register - protocol document - Guidance for super funds on meeting their obligations in relation to lost members and associated reporting obligations.
PAYG
Due date for pay as you go (PAYG) instalment - The due date for payment for annual PAYG instalments is 21 October 2008. Annual instalment notices will be issued in early July 2008 and your clients should be encouraged to pay the full or varied annual instalment before they lodge their income tax returns.
Employment termination payments - when an employee leaves guide - This guide (PDF, 364KB) explains what you need to do when an employee leaves and you are making an employment termination payment (ETP). It will help you make and report the ETP, and calculate the tax amount to be withheld from the payment.
Employment termination payments - when an employee leaves - This guide explains what you need to do when an employee leaves and you are making an employment termination payment (ETP). It will help you make and report the ETP, and calculate the tax amount to be withheld from the payment.
Non Profit News
Non-Profit News Service No. 0202 - Check that your payroll systems are calculating superannuation guarantee correctly - Jun 2008. Changes to super from 1 July 2008 may affect the way non-profit organisations calculate the superannuation guarantee contributions they make for their employees. Organisations are urged to check they have the correct systems to handle the requirement changes and to plan for any additional costs.
Non-Profit News Service No. 0203 - Employer super funds must offer life insurance - Jun 2008. From 1 July 2008, non-profit organisations with employer-nominated super funds (also known as default funds) must offer minimum levels of life insurance death cover to members. This article sets out the requirements employers must comply with.
Superannuation
Searching for lost super - You should complete this form if you want to search our lost members register for any super you may have lost. (NAT 2476)
SuperUpdate June 2008 - SuperUpdate is a monthly electronic newsletter issued to those working in the superannuation industry. It includes information about superannuation issues and changes in the administration of Australia's superannuation system.
Capital Allowances
Capital allowances: effective life review of hairdressing and beauty services assets - Information on the Tax Office review of the effective life of the assets used in hairdressing and beauty services.
Capital allowances: effective life review of sugar manufacturing assets - Information on the Tax Office review of the effective life of the assets used in manufacturing raw sugar, refined sugar and molasses
Capital allowances: effective life review of building and other industrial cleaning service assets - Information on the Tax Office review of the effective life of the assets used various cleaning services, including industrial, office and domestic.
Capital allowances: effective life review of meat processing assets - Information on the Tax Office review of the effective life of the assets used in the meat processing industry.
Capital allowances: effective life review of soft drink, syrup and cordial manufacturing assets - Information on the Tax Office review of the effective life of the assets used in soft drink, syrup and cordial manufacturing assets
Division 7A
Division 7A calculator and decision tool is now available - Broadcast sent on 5 June 2008 to inform tax agents of the Division 7A calculator and decision tool which is designed to assist them in helping their clients comply with their obligations under Division 7A.
FBT
2008 fringe benefits tax returns - deferral of lodgment and final payment date - Broadcast sent on 23 May 2008 to advise tax agents that the Tax Office is currently experiencing delays with processing fringe benefits tax returns and deferral requests for the lodgment of fringe benefits tax returns.
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26. Legislation to be tabled in Parliament on fringe benefit tax arrangements
On 20 June, the Treasurer, the Hon Wayne Swan and Minister for Families, Housing, Community Services & Indigenous Affairs, the Hon Jenny Macklin MP, issued a joint press release which announced that the Government is taking urgent action to ensure employees in the charitable and not-for-profit sector will be protected from the previous Government’s 2006 budget measures, due to come into effect on 1 July 2008.
The Government planned to move urgent amendments in the Senate next week. The amendments will restore the use of the net reportable fringe benefit in income definitions for Family Assistance. This will ensure staff in not-for-profit organisations will not suffer a loss of family tax or child care benefits after 1 July 2008 if their circumstances have not otherwise changed.
It was reported that up to 85,000 Centrelink customers are expected to benefit from this decision and from 23 June, Centrelink call centre staff will be able to advise affected customers of the new arrangements.
However, there are complex issues with flow on effects to employees beyond the not-for-profit sector receiving family assistance. The Government has now asked the Henry Commission to examine the complexity of existing fringe benefit arrangements and make recommendations to improve equity and simplicity in the longer term.
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27. Div 7A – last chance to make corrections
In a press release issued on 19 June, the Commissioner, Mr Michael D’Ascenzo reminded shareholders, business owners and others associated with a private company that they have until 30 June 2008 to take advantage of a one-off opportunity to correct past tax mistakes for payments and loans from private companies without facing penalties or interest.
The Commissioner said that from 1 July 2008, the ATO will resume audit work to ensure payments made by private companies are correctly accounted for and company loans are not used to distribute profits tax-free. He emphasised that penalties and interest will apply after 30 June 2008, unless a tax ruling is obtained.
A Division 7A calculator and decision tool is now available from the ATO website.
A copy of the press release which contains links to the ATO Practice Statement PSLA 2007/20 and other materials including Div 7A calculator is available here.
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Chartered Accountants New Employees Taxation Workshop
Throughout July and August in Sydney, Brisbane, Melbourne, Adelaide and Perth. This intensive two day workshop will provide new employees with the taxation skills and understanding needed to improve productivity in the early stages of employment.
Chartered Accountants Tax Atlas Series
A reference tool that assists in identifying key issues, understanding of key concepts and provisions. Available now: Tax & Wealth Creation; FBT & Salary Packaging; Small Business CGT Concessions.
Cpe.tv
Tax news TV that you can watch from a CD Rom or online. Keep informed on current trends in tax.
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One member writes
Just thought you may be interested. I was just asked for proof of identification reasons by the ATO’s call centre on the tax agents’ hotline to:
- quote the Tax Agent number, even though it came through on their computer because I had punched it in during the call
- quote when a company became GST registered - this is ridiculous because this is not POI, it is publically available on the ABR.
I fail to see the reason behind these questions, when for number 1 it was obvious that I had keyed the TAN in, and for 2 when it is publically available.
Another member writes
I am sick of the letters the ATO send to our clients. Letters to the medical profession regarding claims that they can make and the latest is to clients regarding work related expenses.
When I look at the list of names that they sent letters to, they are young people or clients that have minimal claims in 2007. In fact one client has no taxable income (he only had part time job after leaving school).
Clients who receive these letters ring us as they are concerned whether they have done the right thing, so we need to reassure them. It is an absolute waste of time.
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