Product Ruling

PR 1999/59W

Income tax: Faraday Riding Vineyard Project

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FOI status:

Notice of Withdrawal

Product Ruling PR 1999/59 is withdrawn with effect from today.

We have reviewed the Faraday Riding Vineyard Project and determined that the arrangement, as implemented, is materially different from that described in the Ruling on the following grounds:

1.

the Project arrangement as implemented incorporated a non-arm's length finance provider; and

2.

the Project used an unfunded finance facility for a significant number of investors. For those investors, the project manager was not put in funds directly as a result of the loan.

These features were not disclosed in the application for the Product Ruling. As a result, there is no class of persons to whom the Ruling applies.

Commissioner of Taxation
27 June 2001

References

ATO references:
NO T2000/13746

Related Rulings/Determinations:

PR 98/1
TR 92/1
TR 92/20
TR 97/11
TR 97/16
TD 93/34

Subject References:
carrying on a business
commencement of business
fee expenses
forestry
interest expenses
land clearing
management fees expenses
plantation forestry
primary production
primary production expenses
producing assessable income
product rulings
public rulings
schemes and shams
taxation administration
tax avoidance
tax benefits under tax avoidance schemes
tax shelters
tax shelters project
timber industry

Legislative References:
ITAA 1936 82KL
ITAA 1936 82KZM
ITAA 1936 Pt IVA
ITAA 1936 177A
ITAA 1936 177C
ITAA 1936 177D
ITAA 1997 6-5
ITAA 1997 8-1
ITAA 1997 387A
ITAA 1997 387B
ITAA 1997 387-55
ITAA 1997 387-60
ITAA 1997 387-125
ITAA 1997 387-165
ITAA 1997 387-170
ITAA 1997 387-170(3)
ITAA 1997 387-185
ITAA 1997 995-1(1)