Contract Purchases or Prepayments

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

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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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	a partial rent prepayment was a capital expenditure	261

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

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

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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