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Edited version of private advice
Authorisation Number: 1051915785920
Date of advice: 7 December 2021
Ruling
Subject: Donations to a private ancillary fund
Question 1
Is the sister funda company under section 995-1 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Question 2
In relation to the proposed donation(s) from the sister fund to the fund, would the fund satisfy the rules under section 24 to Part 2 of the Taxation Administration (Private Ancillary Fund) Guidelines 2019?
Answer
The Commissioner has ruled on each of the questions.
This ruling applies for the following periods:
Income years ending 30 June 20XX to 30 June 20XX
The scheme commences on:
01 July 20XX
Relevant facts and circumstances
It is proposed that the sister fund will make donation(s) to the fund.
Relevant legislative provisions
Income Tax Assessment Act 1936
Income Tax Assessment Act 1997