Commissioner of Taxation v Star City Pty Limited (Corrigendum dated 6 March 2009)

• 1. Taxation
  2. › Income tax
  3. › Deductions
  4. › Loss or outgoing of capital or of a capital nature
  5. › Prepayment of rent as lump sum
  6. › Whether prepayment formed part of consideration for grant of casino licence
  7. › Character of advantage sought from practical and business point of view
  8. › Income Tax Assessment Act 1936 (Cth), s 51(1)
  9. › Income Tax Assessment Act 1997 (Cth), s 8-1
• 1. Taxation
  2. › Income tax
  3. › Deductions
  4. › Capital or revenue distinction
  5. › Relevance of surrounding circumstances to characterisation
  6. › Whether court limited to transactional documents in characterising outgoing
  7. › Whether documentary evidence of negotiations admissible
• 1. Taxation
  2. › Income tax
  3. › Anti-avoidance
  4. › Part IVA
  5. › Scheme
  6. › Whether concession by taxpayer that arrangement capable of being scheme precluded primary judge from finding otherwise
  7. › Income Tax Assessment Act 1936 (Cth), s 177A(1)
• 1. Taxation
  2. › Income tax
  3. › Anti-avoidance
  4. › Part IVA
  5. › Tax benefit
  6. › Alternative postulate
  7. › Whether reasonable to expect taxpayer would have paid casino duty base amount and nominal rent absent scheme
  8. › Income Tax Assessment Act 1936 (Cth), s 177C

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