Contract Purchases or Prepayments

See Also

Mussalli v Commissioner of Taxation, [2021] FCAFC 71

Two Australian trusts that were to be the franchisees for seven McDonald’s restaurants agreed, at the same time as they agreed to enter into...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense “rent prepayments” made by new franchisees to reduce percentage rent payments on leases were capital expenditures 216

Mussalli v Commissioner of Taxation, [2020] FCA 544, aff'd [2021] FCAFC 71

Two family trusts (MFT and MIT) agreed to lease restaurant premises from McDonald’s Australia Limited (MAL). The agreements-to lease (FLLs) had...

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Healius Ltd v Commissioner of Taxation, [2019] FCA 2011, rev'd [2020] FCAFC 173

The taxpayer was an Australian public company that provided (including, relevantly, through a subsidiary trust (“Idameneo”) whose results were...

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Words and Phrases
goodwill

Commissioner of Taxation v Sharpcan Pty Ltd, [2019] HCA 36

The taxpayer had been receiving a percentage of the income derived from 18 gaming machines at its hotel premises. However, the licence of the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Concessions and Licences periodic payments under 30-year government concession were currently deductible 206
Tax Topics - Income Tax Act - Section 13 - Subsection 13(34) - Paragraph 13(34)(b) 10-year gaming licences required to maintain existing gaming revenues were not for goodwill 245
Tax Topics - General Concepts - Purpose/Intention purpose distinguished from motive 237

Basell Canada Inc. v. The Queen, 2008 DTC 2108, 2007 TCC 685

A sum of U.S.$16.3 million that the taxpayer paid, at the same time that it purchased a business of the vendor, as consideration for the...

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