Joint Submission by The Taxation Institute of Australia, Institute of Chartered Accountants in Australia, The Australian Society of CPAs, and The Australian Taxpayers Association. Comments on Draft Taxation Ruling TD 1999/D24 Income tax: capital gains: how do Parts 3-1, and 3-5 of the Income Tax Assessment Act 1997 operate if all or part of a liquidator's distributions deemed by subsection 47(1) of the Income Tax Assessment Act 1936 to be a dividend paid out of profits and therefore assessable income of a shareholder under subsection 44(1) of the 1936 Act? General comments 1. Where the Commissioner is expressing his opinion, as a matter of drafting, it is preferable that the Draft Determination should refer to the Commissioner's opinion, rather than using expressions such as we regard/think/consider.
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