Tax Facts

Tax Facts contains news and alerts relating to tax practice, for the benefit of accountants and other professionals in public practice. Please click on the links below for recent issues. You may also like to peruse Tax Facts by topic category - topics are listed below to the right.

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  • SMSF decision hinged critically on trusts law

    In brief:    Much has been said about the Aussiegolfa decision (now on appeal to the Full Court), in which the Federal Court determined that an SMSF had breached the sole purpose test and also exceeded the 5% threshold for in-house assets. The relevant investment was in a unit of student accommodation, acquired under the DomaCom Fund, and a daughter of the SMSF’s sole member was one of 3 students who leased the unit. The member is a state manager for DomaCom and it was admitted that the arrangements were intended to test the use of residential property under the DomaCom system for related parties of SMSFs.

    More:    The sole purpose test was breached because a purpose of the SMSF in acquiring units in the DomaCom Fund was to provide accommodation for the sole member’s daughter. But, in relation to the in-house assets breach, it was a critical finding that the sub-fund established for the property acquisition under the DomaCom Fund constituted a separate trust. The members of the sub-fund were wholly entitled to all the income and capital of the sub-fund, to the exclusion of all other members of DomaCom. Further, it was held that the DomaCom responsible entity owed no fiduciary duties to those other members in respect of the sub-fund. So the sub-fund, even though constituted under a single managed investment scheme and governed by the constitution of the scheme, was held to be a separate trust. This decision serves as a good reminder of the versatility of trusts law. Even though we are accustomed in practice to specific types of trusts (e.g. discretionary trust, child maintenance trust, etc), each typically constituted under a single document, these are not precise species recognised in trusts law. Trusts can be created in many ways and there is enormous flexibility in the terms that can be encompassed. This is part of the reason for the special place of trusts in common law countries and their particular attraction to tax practitioners. (Aussiegolfa Pty Ltd v C of T [2017] FCA 1525)

    ... Read More




    07 Mar 2018

    Topic: SMSFs/Trusts

  • Developing rules for super event-based reporting

    In brief:    The ATO has released a Position Paper on its views for the application of the event-based reporting regime to SMSFs from 1 July 2018. This follows a recent draft legislative instrument to lay down the timing framework for the reporting regime. The basic rule proposed is that reporting must be done within 10 business days after the end of the month in which the reporting event occurred, although that will be subject to further concessions (at least for a transitional period).

    More:    The purpose of the event-base reporting regime is to enable the ATO to track and administer the application of super fund members’ $1.6M (initially) transfer balance account cap. The ATO is seeking feedback about the options outlined in its Position Paper. The first option is the basic rule of 10 business days after the end of the month, but 28 days after the end of the quarter in which the reporting event occurs for reporting of the commencement of a retirement phase income stream and relevant repayment events relating to limited recourse borrowing arrangements. Also, extensions will generally not apply in relation to commutations of income streams. The second option proposed by the ATO is 28 days after the end of the relevant quarter in which the reporting event occurs for an initial 2 year period, reverting to the basic rule of 10 business days after the end of the month for all relevant events (again, except in relation to commutations). (ATO Position Paper; Transfer Balance Cap & SMSF ‘Event-Based’ Reporting Framework, 18 August 2017)

    ... Read More




    24 Aug 2017

    Topic: SMSFs

  • More important super changes

    In brief:    The Government has announced significant changes amongst amendments to the super reforms commencing on 1 July 2017. In relation to limited recourse borrowing arrangements (LRBAs), it is proposed that the outstanding LRBA balance at the end of each year will count towards a member’s Total Superannuation Balance cap of $1.6M. And also that repayments of a LRBA (both principal and interest) will need to be credited to a member’s Transfer Balance Cap. For Transition to Retirement pension (TRIS) accounts, fund earnings are to automatically become exempt when a member turns 65 or satisfies any other nil condition of release. It is intended to enact the amendments before 1 July 2017.

    More:    The proposed changes in relation to LRBAs are to counter perceived distortions to the operation of the reforms. There is a concern, for instance, that the payment of pension liabilities may effectively be made from accumulation phase income using a LRBA, giving an effective transfer of accumulation growth to the retirement phase. And that a member’s Total Superannuation Balance may be artificially kept below the $1.6M cap by lump sum withdrawals that are then lent back to the SMSF under a LRBA. These measures will add further complexity, including the need for apportionments where there is more than one member of a fund. The automatic exemption for TRIS pensions is a welcome one, designed to avoid a compliance need to commute a TRIS on satisfaction of a nil condition of release and recommence an account based pension.

    ... Read More




    06 Apr 2017

    Topic: SMSFs

  • Draft LCGs issued for new super reforms

    In brief:    The Commissioner has issued several draft Law Companion Guidelines in relation to the super reforms commencing on 1 July 2017. Two relate to defined benefit interests but the other 2 are particularly relevant to SMSFs. LCG 2016/D8 covers the transitional CGT relief for assets supporting exempt income streams and which are affected by the $1.6M transfer balance cap or loss of exemption relating to TRIS pensions. LCG 2016/D9 provides guidance about how the $1.6M transfer balance cap operates for account based income streams.

    More:    These LCGs will be useful in helping practitioners digest the new reforms and their implications for clients in various circumstances. That will include potential impacts on estate planning, particularly where reversionary pensions will cause the $1.6M cap to be exceeded after the death of a primary pensioner (although there will be a 12 month window to adjust benefits for the reversionary pensioner in that case). In addition to decisions about potential rearrangements relating to existing income streams and adopting the transitional CGT relief, planning prior to 1 July 2017 should also include maximising both concessional and non-concessional contributions where appropriate.

    ... Read More




    15 Dec 2016

    Topic: SMSFs/CGT/Income Tax

  • New Taxpayer Alert on the diversion of personal services income to SMSF

    In brief:    The Commissioner says in Taxpayer Alert TA 2016/6 that the ATO is reviewing certain arrangements where an individual receives little or no remuneration for services provided to an unrelated party. Instead, income is channelled through another entity to an SMSF in which the individual or their associates are members. The income may be received by the SMSF purportedly as a return on investment in the other entity or on some contractual basis. Apart from the question of whether the income remains assessable to the individual in spite the arrangements, the Commissioner believes that amounts received by the SMSF may constitute contributions to which contributions caps accordingly apply or non-arm's length income to which the highest marginal tax rate applies.

    More:    The arrangements appear somewhat naive and very unlikely to succeed, at least on the basis of the brief description provided in the Alert. Arrangements to attempt to achieve the sorts of aims involved in such circumstances will always be controversial and anyone contemplating them would be well advised to act cautiously and seek specialist advice.

    ... Read More




    26 May 2016

    Topic: SMSFs/Income Tax

  • Another catastrophic error with super contribution caps

    In brief:    An innocent error by a taxpayer, despite engaging and acting on the advice of both a tax agent and financial planner, has resulted in an unexpected tax bill of over $83,000 for excess non-concessional contributions tax. The taxpayer made a non-concessional contribution of $450,000 in the 2011 year of income – the maximum for 3 years at the time under the ‘bring forward’ rule. However, that rule had already inadvertently been triggered in the 2010 year of income and a substantial part of the subsequent contribution of $450,000 constituted an excess contribution. And, in the circumstances, the Administrative Appeals Tribunal held that there were no special circumstances for the purposes of s292-465(3) that would enable part of the contributions to be allocated to a different year of income.

    More:    It is ironic that rules intended to be beneficial for taxpayers can have such catastrophic affects when things go wrong. Although the extreme harshness of the regime with excess contributions has been substantially alleviated from the 2014 year of income onwards. As well as the need to carefully check past contributions, this case is also a good reminder of the importance of communication and coordination if the affairs of a client involve 2 or more advisers. A failure to seek/advise relevant information from and to other client advisers is a dangerous practice that can fairly easily amount to a prima facie case of negligence in appropriate circumstances. (Brady v FC of T [2016] AATA 97)

    ... Read More




    10 Mar 2016

    Topic: SMSFs/Income Tax

  • No changes to SMSF borrowing rules

    In brief:    The Federal Government in its formal response to the Financial System Inquiry (chaired by David Murray) says that it ‘does not agree with the Inquiry's recommendation to prohibit limited recourse borrowing arrangements by superannuation funds.’ However, it will commission the Council of Financial Regulators and the ATO ‘to monitor leverage and risk in the superannuation system and report back to Government after 3 years.'

    More:    So no changes at all are currently proposed to the limited recourse borrowing rules for SMSFs. Coincidentally, in the same week as the Government's response to the Financial System Inquiry, it was reported that ASIC successfully obtained orders in the Supreme Court of New South Wales against a national real estate company held to be wrongly providing financial services. Those services related to recommendations and services about SMSFs provided as part of the company's business of marketing real estate.

    ... Read More




    28 Oct 2015

    Topic: SMSFs

  • Enactment of look-through treatment for SMSF borrowings

    In brief:    Legislation has been enacted to formally adopt look-through treatment in relation to SMSF assets held subject to limited recourse borrowing arrangements. This is achieved by effectively ignoring the custodian trust under which such assets are held, treating the SMSF as the owner and the acts of the custodian trustee as those of the SMSF trustee. So income derived from the assets will be taken to be derived by the SMSF and any CGT event will give rise to a capital gain or loss for the SMSF.

    More:    This change is welcome, although it really only formalises existing practice. It is a pity that the amending Act did not also formalise the practice for GST purposes, although SMSFs will presumably be reasonably comfortable to continue relying on GST Ruling GSTR 2008/3. Under that Ruling, the Commissioner pragmatically accepts that GST supplies and credits effectively occur for the SMSF rather than the custodian trustee. (Tax and Superannuation Laws Amendment (2015 Measures No 2) Act 2015)

    ... Read More




    06 Oct 2015

    Topic: SMSFs/Income Tax

  • SMSF trustees penalised for withdrawals

    In brief:    In this case, a husband and wife were the trustees and only members of their SMSF. A civil penalty of $20,000 was imposed on each of them for various breaches of the SIS laws, together with payment of the Commissioner's costs. The breaches included contravention of the sole purpose rule, lending money to members of the Fund, exceeding in-house assets limits and entering into transactions with related parties on more favourable terms and conditions than would be expected if dealing with those parties at arm's length.

    Subsequent to the sale of an unsuccessful business, they had started to withdraw funds from their SMSF for ordinary living expenses and to meet repayment commitments relating to debt on their former business. Over a 3 year period, they withdrew virtually all the funds from their SMSF, leaving it with only about $6,000 remaining. The trustees were disqualified from being trustees of a super fund and were subsequently also prosecuted for breaches of the relevant SIS laws.

    More:    The penalties in this case were imposed in the context of admission by the trustees of their breaches and their full cooperation with the Commissioner. Nevertheless, there had been prior SIS contraventions, the trustees’ actions were deliberate and they understood that they were contravening the SIS rules. Further, the breaches were serious, with virtually all the assets of the Fund withdrawn. But, having regard to the financial position of the trustees, the Federal Court held that the civil penalties be paid monthly over a 3 year period. (DFC of T v Ryan [2015] FCA 1037) 

    ... Read More




    06 Oct 2015

    Topic: SMSFs

  • SMSF's breaches in connection with buy-sell agreement

    In brief:  A recent Interpretive Decision has expressed the Commissioner's view that breaches of the Superannuation Industry (Supervision) Act 1993 will result from the purchase of a life insurance policy by an SMSF in the circumstances dealt with in the ID. The circumstances postulated are in connection with a buy-sell agreement entered into between 2 brothers who are the only shareholders in a company carrying on a business controlled by the brothers. Under the agreement, the company is to make super contributions to one brother's SMSF, to be used to pay premiums on a life policy held by the trustee of the SMSF on his life. In the event of that member’s death, his spouse will receive the death benefit from the SMSF but his shares in the company are to pass to the deceased's brother for no consideration.

    More:  The Commissioner's view is that the sole purpose test is breached because of the significant objects of the arrangement apart from the SMSF trustee simply holding death cover on the life of a member. Because of the sibling relationship in the circumstances considered, the Commissioner also takes the view that there is a breach of s 65(1)(b) of SIS. That provision prohibits the giving of financial assistance using the resources of the fund to a member of the fund or relative of a member of the fund. The Commissioner believes that such prohibited financial assistance will result, given that the aim of the buy-sell agreement is that the SMSF member's brother will obtain complete ownership of the company without cost in the event of the member's death. (ATO ID 2015/10)

    ... Read More




    07 May 2015

    Topic: SMSFs

  • Another SMSF death benefits case gone wrong

    In brief:  Death benefit nominations for super death benefits are a vitally important matter and it is wrong to treat them glibly. This case is a stark example because the estate of the deceased was very small. So the practical reality was that all the ‘deceased's wealth’ was contained in the SMSF in which he and his second wife were members. Yet his apparent intentions for death benefits from the fund to benefit his 2 daughters from his first marriage, as well as his second wife, were frustrated. It is a very sad and costly saga that could easily have been avoided.

    The outcome in this case would surprise many practitioners, since a purported binding death benefit nomination made by the deceased nominating the "Trustee of Deceased Estate" was held not to comply with the trust deed requirements for a binding nomination or even with the provisions of the SIS Regulations for cashing benefits. It is a good example of why practitioners need to be very careful about death benefit nominations, particularly given limitations under their professional indemnity insurance policies about legal work. The bottom line is that super death benefit nominations are equally important, and warrant the same level of consideration and advice, as the preparation of a person's will.

    More:  The purported binding nomination with the expression, "Trustee of Deceased Estate", was held not to comply with the trust deed requirements or provisions of the SIS Regulations because super death benefits are generally permitted only to dependents of the deceased or the deceased's ‘legal personal representative’, defined to mean the executor of the deceased's will or administrator of his or her estate. Although not commonly appreciated, it is a trite matter of law that the executor of a deceased estate holds an office quite distinct from that of a trustee of estate property (even though the same persons often hold both offices). The failure to address that distinction has resulted in the trustees of the SMSF in this case being left free to exercise discretion about who is to benefit from the deceased's accumulated benefits. That discretion is consequently one exercisable by the deceased's second wife and her daughter, who was appointed as co-trustee after the deceased's death. (Munro v Munro [2015] QSC 61)

    ... Read More




    01 Apr 2015

    Topic: SMSFs

  • Appeal over SMSF death benefits doomed for failure

    The Court of Appeal in West Australia last week dismissed an appeal by the executors of a deceased SMSF member against a decision by the sole surviving trustee to pay the death benefits from the deceased's account to himself.

    The sole surviving trustee was the deceased's husband and the executors were 2 of the deceased's children from a former marriage. The deceased in her will had purported to give her entitlements in the SMSF to her 4 children (stating specifically that she did not want any of her super entitlements paid to her husband), but the executors accepted that the deceased's SMSF interest did not form part of her estate. That purported gift in the will was also inconsistent with 2 separate binding nominations by the deceased in favour of her husband, although both had lapsed before the death of the member.

    The executors had little to support their case. Their first argument was that their stepfather was obliged by s17A of the SIS Act (the provision that defines an SMSF) to appoint one of the executors as a co-trustee and not to make any decision about payment of the death benefits relating to their deceased mother until after that appointment. The second main argument was that their stepfather's decision to pay the death benefits to himself was vitiated by a lack of bona fides. However, there was simply no evidence in the case to support that latter argument and the Court of Appeal held that the provisions of s17A allowing the appointment as trustee of a deceased's executor are permissive only – not a mandatory requirement.

    So a purported gift of super benefits in a person's will, or an expression of wishes in a person's will about who should receive super benefits, will be very unlikely to have any effect unless the superannuation death benefits are paid into the deceased's estate. The real lesson from this case is that certainty about who will receive super death benefits is not achieved by leaving the decision as a discretionary one for surviving trustees. And that effective estate planning requires alignment of a person's will with control mechanisms and decision-making powers under associated SMSFs, trusts and companies. (Ioppolo & Hesford v Conti [2015] WASCA 45)

    ... Read More




    18 Mar 2015

    Topic: SMSFs

  • sham borrowings from private samoan bank

    A purported loan of $600,000 arranged by the taxpayers’ long term accountant from a private Samoan bank controlled by the same accountant was held by the AAT to be a sham. Consequently, the 2 taxpayers were liable to be assessed under former s26AFB of ITAA36 on $300,000 each as receipts out of or attributable to assets of their SMSF, in breach of SIS rules. As a condition of the purported loan, the taxpayers’ SMSF had been required to lodge a $600,000 deposit with the same Samoan bank, which was sent to the bank 3 days before the same amount was received back in Australia as a loan. Further, no interest or loan repayments were made by the taxpayers and their SMSF received no interest on its deposit for over 10 years. Presumably, the fund also was or will be assessed on the basis that it became a non-complying fund.

    In the circumstances, the Tribunal also held that there had been evasion of tax and the normal time limits by which the Commissioner is empowered to amend assessments did not apply. And for good measure, the Commissioner's assessments of administrative penalties (75% for the first year when the purported loan of $600,000 was received and 90% for each of the following years) were also upheld.

    The finding of a sham is an extreme one, although plainly the facts in this case were quite extreme – particularly the actions of the accountant, which were effectively imputed to the taxpayers. It can be quite different where there has been an innocent mistake, even a mistaken view of the law held innocently by a taxpayer's tax adviser. The Commissioner may not be empowered in that case to issue amended assessments after the relevant limitation periods have expired. (Morrison and FC of T [2015] AATA 114)

    ... Read More




    18 Mar 2015

    Topic: Income Tax/SMSFs

  • SMSFs - no "payment" of benefits by journal entries

    In 2 recent interpretive decisions, the Commissioner has expressed the view that the transfer of benefits by journal entry from the account of a deceased member will not amount to the payment of a superannuation death benefit or satisfy the requirement for benefits to be cashed. The hypothetical facts in both interpretive decisions are the same – an intended transfer of benefits in an SMSF by journal entry, from the account of a deceased member to the member's spouse. (ATO Interpretive Decisions 2015/2 and 2015/3)
    ... Read More




    23 Feb 2015

    Topic: SMSFs

  • SMSFs - proposed look through for custodian trusts

    Exposure draft legislation was released this week as part of the implementation of the previous Government's announcement (on 10 March 2010!) to adopt a look through approach for assets of SMSFs held under limited recourse borrowing arrangements. This treatment is also to apply for taxpayers generally, in relation to instalment warrants and receipts relating to listed securities and others in widely held companies.

    For an asset acquired under a limited recourse borrowing arrangement for an SMSF, the custodian trust under which the asset is held will be ignored for most income tax purposes. That is, the income tax regime will operate on the basis that the SMSF is the owner of the asset and acts of the custodian trustee (e.g. sale of the asset) will be taken to be acts of the SMSF. Income and capital gains will consequently be taken to be derived by the SMSF and no tax return will be required for the custodian trust. SMSFs will also be entitled to look through treatment, in the same way as other taxpayers, in relation to eligible instalment receipts not funded by borrowings.

    The draft legislation relates to income tax only – technical GST uncertainties relating to custodian trusts are apparently not to be addressed. Thankfully, the look through approach for income tax is proposed to apply retrospectively back to 1 July 2007 – this recognises that that has been the practice generally adopted anyway.
    ... Read More




    22 Jan 2015

    Topic: SMSFs

  • Interest free loans to SMSFs

    In 2 recent Interpretive Decisions, the Commissioner has concluded that the income derived by SMSFs under limited recourse borrowing arrangements would be non-arm's length income and consequently subject to income tax at the maximum personal rate of 47% (rather than 15%).

    The examples adopted related to the acquisition of both listed shares and real property. In each case, the limited recourse loans were from related parties and were long term (15 years payable by regular instalments and 20 years payable at the end of the loan term). But no interest was payable by the SMSFs to the related party lenders and the LVRs were 80% and 100% respectively.

    Comments from ATO representatives in 2012 (that low or no interest loans from a related party under a limited recourse loan arrangement would not be regarded as resulting in contributions to the relevant SMSF) have fuelled an increase in arrangements with non-arm’s length interest rates. But it is now plain that the ATO will tax the income from such arrangements at 47%. Unless a particular SMSF wants to take issue with the Commissioner on the point, loan terms from related parties (particularly, the interest rate) should be adjusted to the terms that would apply from an unrelated lender and it would be wise for evidence of that to be obtained. (ATO Interpretive Decisions 2014/39 and 2014/40)
    ... Read More




    17 Dec 2014

    Topic: SMSFs

  • Tax Bill No 7 introduced

    The Tax and Superannuation Laws Amendment (2014 Measures No 7) Bill 2014 has been introduced into Parliament. The amendments of most interest are those to enact a less severe regime for excess non-concessional super contributions, to clarify and broaden CGT exemptions relating to personal wrongs, injury, illness and death, and to introduce the exploration development incentive to encourage investments in small exploration companies.

    The super fund amendments will give members the option to withdraw excess non-concessional contributions made from 1 July 2013, together with 85% of associated earnings. No tax will apply to the withdrawn excess contributions, but the associated earnings are to be included in the member's assessable income and taxed at his or her marginal tax rate, with a 15% non-refundable tax offset.

    The exploration development incentive will enable eligible exploration companies to effectively use their tax losses to create exploration credits for investors, giving investors a refundable tax offset (or franking credits in the case of a corporate investor).
    ... Read More




    17 Dec 2014

    Topic: SMSFs/Income Tax

  • Substantial penalties for SMSF breaches

    The Federal Court has recently sanctioned an agreement between the ATO and the directors (husband and wife) of a corporate trustee of an SMSF, for substantial penalties and costs – $40,000 and $10,000 respectively, in aggregate. The Commissioner had already disqualified each of the directors from acting as a trustee, investment manager or custodian of a superannuation entity under s126A(2) of SIS.

    The trustee bought a residence in which the directors’ son lived without paying rent, spend money on a number of things from which no income was produced (a caravan, cattle, 2 cars that were garaged with the directors’ 2 sons, etc) and some expenditure could not be explained. Apart from the cost of the residence, the costs paid (including further costs after the SMSF auditor had filed a Contravention Report) were debited to loan accounts in the names of the directors, amounting to over $250,000.

    Despite the penalties, the directors got off lightly – the amounts were paid back to the SMSF by the directors from other funds and the Commissioner did not make the fund non-complying. The other thing of note is that the penalties in this case were under the civil penalty rules. Under the new administrative penalty regime that started on 1 July 2014, the Commissioner can apply penalties for breaches without seeking any order of the Court. (DC of T v Graham Family Superannuation Pty Ltd [2014] FCA 1101)
    ... Read More




    30 Oct 2014

    Topic: SMSFs

  • Important lessons for estate planning with super

    A recent decision in the Queensland Supreme Court highlights the importance of a valid will and getting things right about who is to benefit from super death benefits. The outcome of the case was apparently contrary to the plain intentions of the deceased and would be seen by many as unfair.

    The deceased was 40 years old at the time of his death and unmarried with no children. Significantly, he died without a will and his estate was therefore subject to the rules of intestacy – in the circumstances, his parents would share his estate equally. His mother applied for, and was granted, Letters of Administration to administer the estate. The estate was only about $80,000 (mainly from a life insurance policy), but there was over $450,000 of superannuation benefits in 3 different funds. The deceased lived with his mother, who had separated from his father when the deceased was only 5 years old.

    There was evidence that the deceased had nominated his mother to receive all super death benefits from the 3 funds, although those nominations were not binding. The mother, on the basis of an interdependency relationship with her son, applied for those benefits and received the full amounts from all 3 funds. The mother was held to have breached her fiduciary duty as administrator of the estate, by applying for the super death benefits for herself rather than for the estate (in which her ex-husband would share equally). She was consequently ordered to account to the estate for all super benefits that she received.

    The outcome is likely to have been different had the deceased made a valid will and appointed his mother as executor. It is quite common for an executor to be a major beneficiary under a will – the duty is far less onerous in that case, since the conflict is imposed by the testator exercising mere testamentary choice. And the deceased's desire to benefit his mother would also have been successful if given effect by way of a binding death benefit nomination. (McIntosh v McIntosh [2014] QSC 99)
    ... Read More




    05 Jun 2014

    Topic: SMSFs/Trusts

  • Final Tax Determination on SMSF bank accounts as segregated current pension assets

    This final Tax Determination was released by the Commissioner last Wednesday. It follows from a draft Determination last August referring to SMSF assets generally (rather than just bank accounts), which was subsequently withdrawn in December. That earlier draft had suggested, unless all fund balances were supporting pension payments, that a separate bank account would be required in relation to pensions in order to constitute a segregated current pension asset. The final determination adopts a less restrictive approach.

    The Commissioner now accepts, if a bank offers sub-accounts, that a sub account may be maintained for the requisite sole purpose relating to the discharge of pension liabilities (even if other sub-accounts are not). More significantly, the division of a single bank account into notional sub-accounts will also be accepted provided that proper accounting records of those notional sub-accounts are maintained by the SMSF trustees. The prompt division between a bank account for pension liabilities and one that is not for that sole purpose, of receipts or payments requiring apportionment between the accounts, will also be accepted (Taxation Determination TD 2014/7).
    ... Read More




    16 Apr 2014

    Topic: SMSFs