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Edited version of private advice
Authorisation Number: 1051972726183
Date of advice: 13 July 2023
Ruling
Subject: CGT - corpus distributions
Question 1
Will the proposed arrangement result in section 97 of the Income Tax Assessment Act 1936 (ITAA 1936) applying to include an amount in your assessable income for the year ended 30 June 20xx?
Answer
No.
Question 2
Will the proposed arrangement result in section 99B of the ITAA 1936 applying to include an amount in your assessable income for the year ended 30 June 20xx?
No.
Answer
No.
Question 3
Will the proposed arrangement result in section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997) applying to include an amount in your assessable income for the year ended 30 June 20xx?
Answer
No.
Question 4
Will the proposed arrangement result in CGT event C2 happening pursuant to section 104-25 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 5
Will the proposed arrangement result in CGT event D1 happening pursuant to section 104-35 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 6
Will the proposed arrangement result in CGT event E4 happening pursuant to section 104-70 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 7
Will the proposed arrangement result in CGT event E5 happening pursuant to section 104-75 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 8
Will the proposed arrangement result in CGT event E6 happening pursuant to section 104-80 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 9
Will the proposed arrangement result in CGT event E7 happening pursuant to section 104-85 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 10
Will the proposed arrangement result in CGT event E8 happening pursuant to section 104-90 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 11
Will the proposed arrangement result in CGT event H2 happening pursuant to section 104-155 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.
Question 12
Will the proposed arrangement result in CGT event K6 happening pursuant to section 104-230 of the ITAA 1997 such that an amount is to be included in your assessable income pursuant to section 102-5 for the year ended 30 June 20xx?
Answer
No.