GENERAL INSTRUCTIONS ON ANSWERING THE TAX ASSIGNMENT1.ANSWER the question in the same ORDER as issues are raised in the question. There is often a logic behind the examiner raising the issues in the...

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GENERAL INSTRUCTIONS ON ANSWERING THE TAX ASSIGNMENT





1.ANSWER the question in the same ORDER as issues are raised in the question. There is often a logic behind the examiner raising the issues in the particular order in the question.





2.The answer must have STRUCTURE. In other words, you must lay the basis for coming to your conclusion on an issue.





3.Generally the manner of structuring your answer will involve the following:





identifying the issue;





making reference to the statute law – particularly identifying which section you are considering (and why you are starting with that section). If parts or phrases of the section are particularly relevant to your answer identifying those parts or phrases in your answer without writing out the whole section;





making reference to relevant case law – do not refer to the facts but the principle established by the cases;





the relevant law/case law will often contain a test that must be satisfied – state the test clearly using your own words;





apply the law/test to your facts and come to a conclusion.





4.USE paragraphing for each new concept. Lack of paragraphing demonstrates a disguising, or lack of understanding, of the issues, and suggests the writer is not prepared to identify and deal with each issue separately.





5.DO NOT have an introduction or any “canvassing” of the issues/law generally at the beginning of your answer. Just identify and start with the first issue raised by the question.





6.DO NOT have a conclusion at the end of the question.





7.DO NOT provide footnotes, bibliography or give citations to the cases. (Note that this advice, and that given in 5 and 6 above, is specific to this subject and is given in the context of problem-based tax questions.)





8.DO NOT discuss the law in isolation from the facts in the question. In marking the question a line will be put through the purported “answer” up to that point where you start dealing with the question.





9.DO NOT use standard check lists.






10.DO NOT offer personal views or opinions such as whether you think something is fair or not.





11.DO proof-read your answer before submitting it. Check that your writing is clear, concise and accurate.









COMPULSORY ASSIGNMENT





Jim is an employee of Modern Kitchens Ltd (Modern Kitchens). He is employed as a carpenter and is paid a salary of $100,000 a year. Modern Kitchens carries on a business of manufacturing and installing new kitchens.





Jim also carries on his own business. He carries on his own business on weekends and outside normal working hours from his home. In his own business he provides handy-man type services and is paid on an hourly basis for the services he renders.





One of the clients that Jim provides his services to, in the course of carrying on his own business, is Quick Repairs Pty Ltd (Quick Repairs). From time-to-time Quick Repairs engages Jim to undertaken urgent weekend repair services for its customers.





Jim is married to Mary and they have a 20-year-old son Jack.





During the 2023 income year (1 July 2022 to 30 June 2023) the following events happen:





(a)Modern Kitchens pays Jim an additional amount of $20,000 in recognition of his excellent work in installing the new kitchens.





(b)A new owner takes over Modern Kitchens by acquiring all of its shares. In order to retain the personnel employed by Modern Kitchens the new owner offers each employee $20,000 in return for their agreement to continue as an employee of Modern Kitchens for the next 12 months. Jim accepts the offer and is paid $20,000.





(c)Modern Kitchens as part of the remuneration package provides its employees with a nil interest loan not exceeding a maximum loan of $100,000. James is provided a loan of $100,000 by Modern Kitchens (at nil interest) which he used to purchase a residential apartment that he intends to rent.





(d)Jim provides services to Quick Repairs on 20 June 2023 and sends an invoice of $1,000 to Quick Repairs for the services rendered allowing 14 days for payment.







(d)Jim receives payment of the invoice on 5 July 2023.





(e)Jim enrolls in a carpentry course costing $2,000 at the local TAFE college which is paid for by Modern Kitchens.





(f)Jim enrolls in a plumbing course costing $5,000 at the local TAFE college which is paid for by Quick Repairs to enable Jim to undertake not only carpentry work for Quick Repairs on weekends but also plumbing work.





(g)In the course of undertaking plumbing work for Quick Repairs Jim replaces an electric water heater with a gas heater. The electric water heater is in good condition and worth $1,000. Jim installs the electric water heater in his home.





(h)Modern Kitchens vacates its office premises over one weekend and moves its business to new premises. Modern Kitchens engages Jack and the children of other employees to assist in cleaning up the former office premises and, for the two days of work, gives each of them a $1,000 gift voucher for use at David Jones stores. The gift voucher is not able to be cashed in or transferred.





(i)In consideration for Jim performing services worth $5,000 for Quick Repairs, Quick Repairs provided $5,000 worth of electrical services to Jim by installing new electrical wiring in his home.





(j)Jim does minor carpentry work repairing a fence for his next-door neighbour who is 90 years old. The work only takes a couple of hours and Jim does not want any payment for the work. However, the neighbour insists on giving Jim $10.





Advise Jim, Mary, Jack and Modern Kitchens as to whether they are assessable (under the income tax or fringe benefits legislation) in respect of the amounts/benefits received and provided under the above scenarios for the income year ended 30 June 2023.





[Students are not required to consider deductibility or to undertake any calculations of the tax payable in answering this question but, if applicable, should consider the “otherwise deductible rule” under the relevant legislation.

Answered 6 days AfterJan 03, 2024

Answer To: GENERAL INSTRUCTIONS ON ANSWERING THE TAX ASSIGNMENT1.ANSWER the question in the same ORDER as...

Deblina answered on Jan 09 2024
29 Votes
TAX ASSIGNMENT
Table of Contents
Analysis of the Events    3
Additional Payment of $20,000 from Modern Kitchens: Assessable Income    3
$20,000 from New Owner to Retain Employment: Assessable Income    3
Nil Interest Loan of $100,000 from Modern Kitchens: Potential Division 7A Implication    4
Services Rendered to Quick Repairs & Invoiced $1,000: Assessable Income    4
Recommendation    5
Analysis of the Event
s
Additional Payment of $20,000 from Modern Kitchens: Assessable Income
Under the Income Tax Assessment Act 1997 (ITAA 1997), assessable income encompasses various forms of income, including payments directly linked to employment. Section 6-5 of the ITAA 1997 defines assessable income as ordinary income derived from multiple sources. Case law, such as Scott v. Commissioner of Taxation [1966] HCA 56, establishes that payments received due to employment relationships typically fall within the ambit of assessable income.
The $20,000 payment received by Jim from Modern Kitchens, acknowledging his exceptional work in the context of his employment as a carpenter, aligns with this understanding. This payment is directly connected to Jim's employment relationship with Modern Kitchens and is a recognition of his outstanding performance, consistent with his duties as an employee. As such, based on the principles outlined in Section 6-5 of the ITAA 1997 and supported by relevant case law, the $20,000 payment constitutes assessable income for Jim.
Therefore, according to Australian tax regulations and established case law, the $20,000 additional payment received by Jim from Modern Kitchens due to his exceptional work within his employment is deemed assessable income, requiring inclusion in Jim's taxable income for the relevant financial year.
$20,000 from New Owner to Retain Employment: Assessable Income
Under the Income Tax Assessment Act 1997 (ITAA 1997), assessable income encompasses various forms of income, including payments received due to employment relationships. In accordance with case law such as Scott v. Commissioner of Taxation [1966] HCA 56, payments received for the continuation or retention of employment typically fall within the definition of assessable income. Therefore, the $20,000 received by Jim from the new owner to retain his employment aligns with this understanding. As it corresponds to an employment-related arrangement and complies with the fundamental principles outlined in the ITAA 1997 and supported by relevant case law, this payment constitutes assessable income.
Nil Interest Loan of $100,000 from Modern Kitchens: Potential Division 7A Implication
Division 7A of the Income Tax Assessment Act 1936 (ITAA 1936) governs loans from private companies to their shareholders, associates, or employees. It aims to prevent the tax-free distribution of company profits through loans or advances. Notably, when a private company provides a loan to an employee at nil or low interest rates, it might trigger Division 7A implications. Case law such as Everett v. Federal Commissioner of Taxation [1980] HCA 2 establishes that loans from private companies might be treated as assessable income if not structured in compliance with Division 7A requirements. Hence, Jim's receipt of a nil interest loan of $100,000 from Modern Kitchens potentially falls within the purview of Division 7A. This necessitates a detailed examination to ascertain whether the loan complies with Division 7A provisions and to determine any tax implications that may arise.
Services Rendered to Quick Repairs & Invoiced $1,000: Assessable Income
In line with Section 6-5 of the ITAA 1997, assessable income comprises ordinary income derived from various sources, including income generated from services rendered. Case law, such as FC of T v. Rowe (1997) 34 ATR 520, establishes that income derived from independent business activities, such as providing services and invoicing for remuneration, constitutes assessable income. Jim's invoicing of $1,000 to Quick Repairs for services rendered aligns with...
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