Disclaimer
This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law.

You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4.

Edited version of your written advice

Authorisation Number: 1012692236356

Advice

Subject: Share issue

The Commissioner issued an Administratively Binding Advice in relation to a share issue. The Commissioner considered a number of income tax provisions including those contained in Divisions 202 and 207 of the Income Tax Assessment Act 1997, and those contained in Division 11A and Part IVA of the Income Tax Assessment Act 1936.