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Edited version of your written advice
Authorisation Number: 1051231958149
Date of advice: 22 August 2017
Ruling
Subject: Division 250 of the Income Tax Assessment Act 1997
The ruling concerned the following:
● Will section 250-15 of the Income Tax Assessment Act 1997 (ITAA 1997) be satisfied in respect of a taxpayer and certain assets?
● Where the general test in section 250-15 of the ITAA 1997 is satisfied in respect of the taxpayer and certain assets, will the Commissioner make a determination under section 250-45 of the ITAA 1997 that it is unreasonable that Division 250 applies in respect of the taxpayer and certain assets?
The Commissioner has ruled that:
Section 250-15 of the ITAA 1997 will be satisfied in respect of a taxpayer and certain assets. However, the Commissioner will make a determination under section 250-45 of the ITAA 1997 that it is unreasonable that Division 250 applies in respect of the taxpayer and those assets.