Assignment Task One – (1,000 words – 15 Marks)
Mr. Bony Abbot, your client was born in Melbourne and lived in Australia until 2 July of the current tax year. At that stage, he accepted a voluntary redundancy with Virgin Australia. A year earlier he had separated from his wife of 20 years. A few months later he started a relationship with a resident of Singapore.
Upon accepting the redundancy, he began travelling overseas to perform aircraft mechanic services at various locations within Asia. Under his contract of employment with Boeing, the taxpayer was provided with either hotel or short-term apartment accommodation at each location he attended for work purposes.
During the current income year, the taxpayer provided services in Malaysia, Portugal, Italy and Indonesia. The longest time he stayed at any one place was 45 days in a serviced apartment in Italy. The taxpayer visited his two teenage children and his parents in Australia on two occasions for a total of 30 days and visited his new partner in Singapore on four occasions for a total of 50 days. During the tax year what had been the family home in Melbourne was sold to complete a divorce settlement. While he no longer had any place in Australia in respect of which he could call his own, he also did not have ownership or leasehold in any dwelling outside Australia. Nor did he apply for a long-term visa or residency status anywhere outside Australia.
Advise your client whether he is a resident of Australia in the current tax year for income tax purposes.
(Your answer should assume the taxpayer was able to travel normally and without Covid-19 restrictions during the period under consideration.)
Required
In a professional letter (not exceeding 1,000 words) from you, the tax adviser, to advise Mr Bony Abbot whether at 30 June 2022 he will be assessed as a resident of Australia for income tax purposes.
Also advise Mr. Abbot how his income will be assessed given both scenarios of his being deemed a resident or a non-resident of Australia for taxation purposes.
Show appropriate referencing to case law, sections of the ITAA 1936 and ITAA 1997 and income tax rulings issued by the Australian Taxation Office. Ignore any consequences of the Double Tax Agreement between Australia and countries he has worked in.
State the word count in your submission.
Assignment Task Two (1,000 words – 10 marks)
On 5 June 2021, G-7 finance ministers in London from the United States, Britain and other leading nations reached a landmark deal to pursue higher global taxation on multinational businesses such as Google, Apple and Amazon.
The Group of Seven (G-7) large advanced economies agreed to back a minimum global corporate rate of at least 15 per cent and for companies to pay more tax in the markets where they sell goods and services.
Many nations have struggled for years to agree a way to raise more revenue from large multinationals such as Google, Amazon and Facebook, which often book profits in jurisdictions where they pay little or no tax.
Critically discuss the justification for and against the implementation of a minimum global corporate tax rate. 7 marks
Reflect on the impact of the above implementation to your career plan. 3 marks
Total – 10 marks
Required
Present in a report format (not exceeding 1,000 words)
State the word count in your submission.