In this episode of the Herbert Smith Freehills Kramer Tax Bites podcast, Isaac Morgan, Mark Peters and Toby Eggleston discuss the recent Australian High Court decision in G Global against the Commissioner of State Revenue. The conversation delves into the background, statutory setup, and arguments presented in the case, exploring the implications for foreign investors and potential future legal challenges. The episode also examines retrospective tax amendments and their broader impacts on t...
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In this episode of the Herbert Smith Freehills Kramer Tax Bites podcast, Isaac Morgan, Mark Peters and Toby Eggleston discuss the recent Australian High Court decision in G Global against the Commissioner of State Revenue. The conversation delves into the background, statutory setup, and arguments presented in the case, exploring the implications for foreign investors and potential future legal challenges. The episode also examines retrospective tax amendments and their broader impacts on t...
In this episode of the Herbert Smith Freehills Kramer Tax Bites podcast, Isaac Morgan, Mark Peters and Toby Eggleston discuss the recent Australian High Court decision in G Global against the Commissioner of State Revenue. The conversation delves into the background, statutory setup, and arguments presented in the case, exploring the implications for foreign investors and potential future legal challenges. The episode also examines retrospective tax amendments and their broader impacts on t...
In this episode of the Herbert Smith Freehills Kramer 'Tax Bites' podcast, host Toby Eggleston alongside Professor Graeme Cooper and fellow partner Ryan Leslie, explore the complexities of the third party debt test as it relates to Australia's thin capitalisation rules. Key discussions include the overview and operational intricacies of the third party debt test introduced to replace the arm's length debt test, the guidance and issues arising from the ATO, and the impact of these chang...
In this episode of the Herbert Smith Freehills Kramer Tax Bites podcast, hosts Toby Eggleston and Professor Graham Cooper discuss the significant implications of the proposed Section 899 under President Trump's 'One Big, Beautiful Bill' Act. They delve into how these retaliatory taxes imposed by the US aim to counteract what are perceived to be unfair or discriminatory foreign taxes, particularly affecting Australian companies. The discussion covers the legislative background, specific unfair...
In this episode of the Herbert Smith Freehills Tax Podcast, partner Toby Eggleston and consulting Professor Graham Cooper discuss recent tax policy announcements from both major political parties in light of the upcoming election. They focus on measures affecting large businesses, small businesses, and individuals and on unenacted measures and the implications of these policies for businesses and taxpayers. also touch on the impact of global tax trends, specifically the OECD’s pillar one and ...
In this quickfire episode of the Herbert Smith Freehills Tax Bites podcast, Australian tax partners Toby Eggleston and Ryan Leslie, along with Senior Associate Naison Seery, discuss the recently released Treasury consultation paper proposing changes to the foreign resident capital gains tax regime. Key topics include broadening the classification of assets subject to tax, updates to the principal asset test to a 365-day rule, and new notification requirements for the sale of assets over $20 m...
In this special late night edition of the Tax Bites podcast Professor Graham Cooper, Nick Heggart, Ryan Leslie and Toby Eggleston delve into the key tax-related aspects of Budget 2024. The discussion begins with general observations about the budget's minimalistic approach to new tax measures before shifting to specific changes, such as the unexpected adjustments to the capital gains tax (CGT) regime for non-residents, aiming to align with OECD standards, yet raising questions about compatibi...
In this episode of the Herbert Smith Freehills Tax Bites podcast, Toby Eggleston partners with Consulting Professor Graham Cooper and fellow partner Ryan Leslie to dive deep into recent Federal Court decisions on the anti-avoidance provisions in Part IVA of the Income Tax Assessment Act 1936. The discussion begins with insights into the Minerva Financial Group vs. Commissioner of Taxation, highlighting the saga of restructuring for an IPO and the accompanying tax implications. Also explored i...
In this episode associate Mark Peters and partner Toby Eggleston discuss the potentially huge changes to the stamp duty regime in Victoria for commercial property. While it initially sounds straightforward, there are a number of nuances and potential issues for future transactions. More details can be found in our tax insights.
In this episode associate Geraldine Chan and partner Ryan Leslie join Toby Eggleston to discuss the main takeaways of the Commissioner’s win in the PepsiCo case. More details can be found in our tax insights blog.
In this episode new partner James Pettigrew and Professor Graeme Cooper joins Toby Eggleston to discuss the proposed debt creation regime, dropped into the thin capitalisation bill at the last minute. More details can be found in our tax insights here.
In this episode stamp duty specialists Jinny Chaimungkalanont and Dan Miles educate income tax partner Toby Eggleston on the latest developments in Australian state taxes. Topics include the Victorian State budget, NSW changes to landholder duty for listed entity takeovers (look out!), NT and WA updates and rounding it out with a summary of 3 important cases handed down in May. More details can be found in our tax insights: 2023-24 Budget Update: Key changes to Australian state taxes (...
In this episode partners Toby Eggleston, Ryan Leslie and Nick Heggart and consulting Professor Graeme Cooper breakdown the Australian Federal budget and the implications for large taxpayers. Topics include proposed changes to Part IVA, build to rent incentives, Pillar 2 update and a special section for the mining sector. All you need in 26 minutes! More details can be found in our tax insight: https://hsfnotes.com/taxaustralia/2023/05/09/tax-insight-tax-measures-in-australias-2023-24-budget/
In this episode in our Tax Bites series, Professor Graeme Cooper and partners Ryan Leslie and Toby Eggleston unpack the just released Exposure Draft on changes to Australia’s thin capitalisation regime aimed at limiting interest deductions for Australian taxpayers. 30 years of tax history packed into under 30 minutes! More details here: https://hsfnotes.com/taxaustralia/2023/03/17/tax-insight-new-limits-on-deducting-interest/
In this episode Mark Peters and Toby Eggleston discuss the latest in the world of NSW stamp duty. A must listen for those in property and infrastructure. More details can be found on blog here: https://hsfnotes.com/taxaustralia/2022/11/15/nsw-stamp-duty-reforms-change-of-beneficial-ownership-where-have-we-landed-significant-changes-to-leases-and-option-transactions/
In this episode Professor Graeme Cooper and partner Toby Eggleston dissect the Treasury Consultation Paper on Multinational tax integrity and enhanced tax transparency. More details can be found on blog here: https://hsfnotes.com/taxaustralia/2022/08/15/tax-insight-treasury-consultation-paper-international-tax-measures/
In the first episode of our Tax Bites podcast series, Stamp duty partner Jinny Chaimungkalanont enlightens tax partner Toby Eggleston on all the happenings in the world of stamp duty.
In this episode of the Herbert Smith Freehills Kramer Tax Bites podcast, Isaac Morgan, Mark Peters and Toby Eggleston discuss the recent Australian High Court decision in G Global against the Commissioner of State Revenue. The conversation delves into the background, statutory setup, and arguments presented in the case, exploring the implications for foreign investors and potential future legal challenges. The episode also examines retrospective tax amendments and their broader impacts on t...
