The ATO has recently issued taxpayer alert TA 2021/2, which relates to arrangements where an Australian tax resident’s foreign income is disguised as gifts or loans from related offshore entities.

There has been a lot of discussion about how non-arm’s length income (NALI) and non-arm’s length expenditure (NALE) apply to self-managed superannuation funds...

The story of Greensill’s capital gains is not a happy one. But there are important lessons for advisers acting for trusts that distribute capital gains to non-resident beneficiaries.