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The capital/revenue distinction in financial services paper


This paper covers:

  • when is a gain on realisation of an asset ordinary income?
  • application to financial services businesses
  • impact of the consolidation rules on the analysis.

Author profile

Eugene Wheelahan QC FTI
Eugene Wheelahan QC, FTI, is a member of the Victorian Bar who practises principally in the area of tax. He has appeared for taxpayers and the Commissioner of Taxation in the Federal Court and the High Court. He acts for clients in the mining, infrastructure, telecommunications and financial services industries, among others, providing opinions and assisting them in their dealings with the Commissioner during reviews, audits, objections and litigation. Eugene has a Master of Tax from the University of Melbourne where he is a Senior Fellow of the Law Faculty, lecturing in the subjects Tax Litigation and Tax Avoidance and Planning. - Current at 15 June 2022
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This was presented at 2020 Financial Services Taxation Conference .

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